The export of certain technologies, software and hardware is regulated and controlled by Federal law for reasons of national security, foreign policy, competitive trade reasons and to prevent the spread of weapons of mass destruction. SIT and all its employees are required to comply with the laws and implementing regulations issued by the Department of State through its International Traffic in Arms Regulations ("ITAR"), the Department of Commerce through its Export Administration Regulations ("EAR") and the Department of the Treasury through its Office of Foreign Asset Controls ("OFAC").
World events dictate the increased need for security and vigilance over the technology controlled on the Department of State's United States Munitions List ("USML") and the Department Commerce's Commerce Control List ("CCL"). Accordingly, the importance and scrutiny for compliance with the regulations has increased and research contracts and agreements received by universities from sponsors, both Federal and non-federal, which contain export control provisions have increased significantly. Export control regulations apply regardless of the source of funding, both external and internal.
Although most research conducted on U.S. college and university campuses is excluded from these regulations under the Fundamental Research Exclusion, university research involving specified technologies controlled under the EAR and/or ITAR, or transactions and exchanges with designated countries, individuals and entities may require SIT to obtain prior approval from the appropriate agency before allowing foreign nationals to participate in controlled research, collaborating with a foreign company and/or sharing research - verbally or in writing - with persons who are not U.S. citizens or permanent residents. Export control regulations affect not only research conducted on campus, but also travel and shipping items outside the U.S. Simply traveling to certain sanctioned countries could require a license from OFAC. OFAC sanctions prohibit transactions and the exchange of goods and services in certain countries and with designated persons and entities. SIT is committed to export control compliance, and the export control compliance function within the Office of Sponsored Research is staffed to advise and assist faculty in conducting activities related to research and sponsored projects. More information regarding these and other regulations that impact university activities can be found at the Department of Commerce/BIS website; the Department of State/ITAR website; and the Department of the Treasury/OFAC website.