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Appendix B: Export Controls Overview

  1. U.S. federal regulations and sanctions promulgated and enforced by various federal agencies, including the Department of Commerce, Export Administration Regulations (EAR); the Department of State, International Traffic in Arms Regulations (ITAR); and the Department of Treasury, Office of Foreign Assets Control (OFAC), prohibit the unlicensed transfer of specific technologies and items and payments to certain entities and individuals for reasons of national security or protection of trade.
  2. While 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 the University either to obtain prior approval in the form of a license or to document a license exception from the appropriate agency before allowing foreign nationals to participate in controlled research, collaboration with a foreign company, and/or sharing research—verbally or in writing—with persons who are not U.S. citizens or permanent residents. 
  3. Additionally, some international interactions are prohibited because of OFAC regulations proscribing the provision of anything of value to certain countries. Pursuant to these regulations, “anything of value” includes conference presentations and professional conversations (with or without payment).
  4. The consequences of violating these regulations can be severe, ranging from loss of research contracts to monetary and criminal penalties for the individual and/or organization violating these regulations.
  5. Export control implications for your international UA travel depend on
    1. What you take (laptop, cell phone, software, data, schematics, equipment);
    2. With whom you associate or do business (denied lists); and
    3. The country you are traveling to.
      Travel to Iran, Syria, Cuba, Sudan, North Korea, and Libya are the most restrictive! UA travel to Iran and Syria is not permitted. Travel to the other four destinations noted (i.e., Cuba, Sudan, Libya, and North Korea) is subject to significant export control restrictions and other economic sanctions and embargoes.

More information on export controls can be found at the Office for the Responsible Conduct of Research, Export Controls website and by contacting Kay Ellis, Export Control Officer, at (520) 626-2437 or via email at ellisk@email.arizona.edu.