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Export Controls

 

What are export controls?

Export controls are the set of regulations governing the shipment of goods abroad, as well as the dissemination of information to non-U.S. citizens both abroad and within the U.S. In an academic setting, export controls regulate who you can collaborate with on research, what students can work on your research, and where you can travel abroad and what you may take with you when you do. 

More than merely regulating how to ship items out of the country, it is important to know the basics of export control as unexpected activities can lead to export control violations. For example, having an ITAR controlled infrared camera unlocked in a lab is a potential violation. Another is teaching non-introductory level STEM courses to nationals from certain sanctioned countries. Both of these potential violations can occur without leaving campus and thus demonstrate the importance of learning the regulations and policy.

In an academic setting, there are several common activities that can potentially trigger export controls:

· International Travel

· Proprietary/Restricted Research

· Working with Foreign Students or Researchers
(Abroad and within the US)

 

American University's Policy

The current Export Control Policy for American University is linked here:

Export Control Regulations

International Traffic in Arms Regulation (ITAR)- Administered by the Department of State, this set of regulations handles military use equipment and services, including items listed on the United States Munitions List.

Export Administration Regulations (EAR)- Administered by the Department of Commerce, Bureau of Industry and Security, this set of regulations handles items considered to be "dual-use", meaning potential military and civilian uses as well as all commercial goods.

Office of Foreign Asset Control (OFAC)- Administered by the Department of the Treasury, this office administers the boycotts and sanctions programs that the United States currently imposes. This limits who one can do business with or share research with both abroad and within the U.S.

 

Enforcement and Penalties

In recent years, the government has increased its enforcement of export controls with regards to universities as focus has intensified over national security. As such there have been cases where professors and/or the university have been prosecuted for violations of these export controls. Such violations carry civil and criminal penalties which can reach up to $1,000,000 and 10 years in prison per violation.

 

Other Resources

Frequently Asked Questions & Common Terms

 

Training

American University affiliates can access export controls training on the CITI website.

New users should register an account and affiliate with American University. For export controls, you only need to select Question 4 - "US Export Control" and decline the others. If you have already taken a CITI course for other purposes, you can add the export controls module by using the "Add Course or Update Learner Groups" and add Question 4 to the learner profile.