Export Control

Complying with U.S. export laws and regulations

To promote national security interests and foreign policy objectives, the U.S. government regulates the transfer of items, information, commodities, technology, and software outside of the U.S. and to foreign persons within the U.S. Such a transfer, called an export, includes oral, written, electronic or visual disclosure; physical shipment; hand-carrying items while traveling; and providing technical assistance.

Export regulations may also affect:

  • collaborations with international research partners
  • how you disseminate research results
  • travel abroad for teaching and research purposes
  • purchasing and procurement transactions with restricted countries and restricted end users

Resources and training

If you have any questions about the export or use of equipment and technologies, the resources listed below may help:

Recordkeeping Requirements

To comply with U.S. export control laws, the university is required to maintain records related to exports and transactions involving restricted or sanctioned parties. These records are essential for demonstrating compliance and must be retained according to the specific requirements set by federal regulations.

Under the Export Administration Regulations (EAR), governed by the U.S. Department of Commerce, records must be kept for five years from the date of the export, reexport, or any other relevant activity. See 15 C.F.R. § 762.6.

The International Traffic in Arms Regulations (ITAR), administered by the U.S. Department of State, require records to be maintained for five years from the expiration of a license or other authorization, or from the date of a transaction if no license was required. See 22 C.F.R. § 122.5.

For transactions subject to the Office of Foreign Assets Control (OFAC) regulations, records must be retained for ten years from the date of the transaction or from the date any blocked property is released or transferred. See 31 C.F.R. § 501.601.

All university personnel involved in export-controlled activities must ensure that appropriate records are securely maintained for the required period.