The University is committed to complying with U.S. export controls. No University faculty, staff, or student may engage in any activity, or commit the University to engage in any activity that violates U.S. export control laws and regulations. Specifically, personnel may not:
- export commodities, software, or technology subject to the Export Administration Regulations (EAR), except as authorized by the U.S. Department of Commerce;
- export hardware, technical data, or services subject to the International Traffic in Arms Regulations (ITAR), except as authorized by the U.S. Department of State;
- engage in transactions subject to the Foreign Assets Control Regulations, except as authorized by the U.S. Department of the Treasury; or
- violate any other U.S. export control law or regulation.
Faculty, staff, and students involved in research and academic projects that are subject to export controls must follow the requirements that are appropriate for the roles they serve. These individuals are responsible for reviewing the materials on the University's export controls website and consulting the Export Controls Officer when export controls apply.
Reason for Policy
This policy codifies the University's commitment to compliance with U.S. export controls, identifies the corresponding responsibilities of University personnel, and establishes the administrative foundation for the University's export controls compliance program. These steps are required to ensure the University's compliance with U.S. export controls.
The University recognizes the importance of these laws and regulations, and expects compliance from all of its personnel. Violations can result not only in significant civil or criminal liabilities for the University and potentially the individuals involved, but also in damage to national security and to the University's standing as a premier institution of research and learning.