University of Rochester Guidance for Complying with U.S. Export Controls
The University of Rochester is committed to complying with U.S. export control laws and regulations, including the International Traffic in Arms Regulations (ITAR) administered by the Department of State, the Export Administration Regulations (EAR) administered by the Department of Commerce, and the specific economic and trade sanctions administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC).
It is important that the University community be familiar with U.S. export control laws in order to ensure compliance. University faculty, staff and students are expected to identify potential export related concerns (e.g. sending/carrying an item out of the U.S.; publication approval clauses; restrictions on project personnel participation; receipt of export controlled information or an ITAR controlled item) and notify email@example.com or the Office of Research and Project Administration in advance of any research proposal submission or potential export (including a deemed export).
An overview of U.S. export control laws for the University of Rochester community is available online: https://www.rochester.edu/orpa/compliance/export/us/
Teaching and information resulting from research at the University of Rochester are largely not subject to U.S. export control laws because they result from fundamental research, are published and/or constitute information concerning general scientific, mathematical, or engineering principles commonly taught at a university. That said, the University may need to apply for and receive an export license if sending an export controlled item out of the U.S. Also, situations may exist in which the University may need to apply for and receive a deemed export license and/or implement a technology control plan if receiving or developing export controlled information (e.g. under a confidentiality agreement), or working with an ITAR controlled item. Such a technology control plan must be reviewed by the Committee on Science and Security (chaired by Rick Waugh, Vice Provost for Research) and will include:
- University commitment to export compliance
- Description of the export control item and/or information
- Project personnel (and restricted party screening)
- Physical security controls
- IT security controls
Certain projects that are approved by the President of the University as an exception to the University’s policy on OPEN RESEARCH AND FREE DISSEMINATION OF IDEAS AND INFORMATION may be subject to export control laws and require access restrictions for personnel to work on the project. Any export controlled projects must be clearly defined, reviewed by the Committee on Science and Security, and a corresponding technology control plan shall be implemented.
Violations of U.S export control laws may be subject to both criminal and significant administrative penalties, and violators may also lose their export privileges.
Any questions regarding U.S. export compliance, including requests for export compliance training, may be directed to: Josef Mejido, Export Control Officer