Printed on: 05/13/2025. Please go to policy.umn.edu for the most current version of the document.
University of Minnesota  Administrative Policy

Export Controls

Sidebar

Expand all

Sidebar

Table of Contents

Questions?

Please use the contact section below.

Leave Feedback

Policy Statement

The University is committed to complying with U.S. export controls. No University faculty, staff, or student may engage, or cause the University to engage, in any activity that violates U.S. export control laws and regulations. Specifically, personnel may not:

  • export commodities, software, technology, or services 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 appropriate requirements for their roles. These individuals are responsible for consulting the University's export controls website and working with the Export Controls and Research Security team (ECRS) when export controls apply.

Reason for Policy

This policy codifies the University's commitment to comply 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. The University recognizes the importance of these laws and regulations, and expects compliance from all of its personnel. Violations may result in significant civil or criminal liabilities for the University and individuals involved, as well as harm to national security and the University's standing as a premier institution of research and learning.

Contacts

SubjectContactPhoneEmail
Primary Contact(s)J. Patrick Briscoe, Export Controls and International Projects Officer612-625-3860[email protected]
Research Integrity and Compliance (RIC)Danielle Rintala, RIC Director612-624-8349[email protected]
Office of General CounselArnie Frishman612-624-5155[email protected]
Responsible Individuals
Responsible Officer Policy Owner Primary Contact
  • Vice President for Research and Innovation
  • Research Integrity and Compliance Director
  • J Patrick Briscoe
    Export Controls and International Projects Officer
  • Danielle Rintala
    Research Integrity and Compliance Director

Definitions

Export

  • The shipment, transmission, or carriage of items out of the U.S.;
  • The transfer or release of export-controlled software, technology, or technical data to a non-U.S. person located in the U.S. (a “deemed export”); or
  • The performance of a regulated service subject to the ITAR or EAR on behalf of, or for the benefit of, a non-U.S. person.

Export Administration Regulations (EAR)

Regulations (15 CFR Parts 730-774) administered by the U.S. Department of Commerce, Bureau of Industry and Security, that prohibit the unauthorized export of:

  • Commodities, software, and technologies identified on the Commerce Control List;
  • Certain items to restricted parties on the Entity, Military End-User, Unverified, and Denied Persons Lists; and
  • Items and services to be used for military, intelligence, or security end-uses.

Export Controls

U.S. Government statutes and regulations that prohibit the unauthorized export of certain commodities, technologies, software, services, money, or information to non-U.S. destinations, persons, and entities (including universities). Export controls implement a range of national obligations and interests, such as honoring non-proliferation treaties, protecting national security, and combating terrorism.

Export Controls and Research Security (ECRS) Team

The group within the Research and Innovation Office responsible for system-wide compliance with export controls research security rules, and related requirements.

Foreign Assets Control Regulations

Economic sanctions regulations (31 CFR Parts 500-598) administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, that prohibit unauthorized transactions with embargoed countries and entities identified on the Specially Designated Nationals and Blocked Persons List, Sectoral Sanctions Identification List, and certain other sanctions lists.

Foreign Person (or Non-U.S. Person)

  • An individual who is not a U.S. (or dual U.S.) citizen or permanent resident of the U.S., and who has not been granted political asylum or other protected status;
  • A corporation, business association, partnership, trust, society, or any other entity or group that is not incorporated or organized to do business in the U.S.; or
  • An international organization or foreign government (including agencies or subdivisions).

Fundamental Research

Basic and applied research in science, engineering, or mathematics where the resulting information is ordinarily published and shared broadly within the scientific community, as distinguished from research, the results of which are restricted for proprietary reasons or specific U.S. Government access and dissemination controls. The information that results from or arises during fundamental research (aside from certain encryption source code) is excluded from export controls.

International Travel

Travel to any country or territory outside the continental U.S. and other non-foreign U.S. overseas locations (Alaska, Hawaii, American Samoa, Guam, Midway Islands, Northern Mariana Islands, Puerto Rico, U.S. Virgin Islands, and Wake Island).

Travel to Canada and Mexico is considered international travel.

International Traffic in Arms Regulations (ITAR)

Regulations (22 CFR Parts 120-130) administered by the U.S. Department of State, Directorate of Defense Trade Controls, that prohibit the unauthorized export or brokering of defense articles and defense services. Defense articles are the hardware, software, and technical data identified on the U.S. Munitions List. Defense services include technical assistance furnished to non-U.S. persons in connection with defense articles, among other services.

Research Integrity and Compliance (RIC) Office

Unit responsible for overseeing the research enterprise's compliance with relevant regulatory and ethical standards. ECRS resides within RIC.

U.S. Person

  • An individual who is a U.S. (or dual U.S.) citizen or lawful permanent resident of the U.S., or who has been granted political asylum or other protected status;
  • A corporation, business association, partnership, trust, society, or any other entity or group that is incorporated or organized to do business in the U.S.; or
  • A federal, state, or municipal governmental entity in the U.S.

Responsibilities

Associate Director, Export Controls and Research Security

Responsible for managing the University's export controls compliance program, as part of the Research Integrity and Compliance group. Serves as a central resource for principal investigators and grant administrators on issues related to export controls; assesses restrictions on international travel and research awards; works closely with the Office of the General Counsel regarding the resolution of problematic terms and conditions in awards; oversees export control education requirements; obtains export licenses as required; serves as one of the University's two Empowered Officials. 

Controller's Office

Responsible for the U Travel Program, External Sales, and Purchasing.

Deans, Department Heads, and Chairs

Responsible for routing questions about export controls to ECRS, taking offered training in export control regulations and being aware of the export controls relating to the area(s) of research that are under their purview.

Departmental Grant Administrators

Responsible for being aware of policies and procedures related to export control regulations as may pertain to the administrator's area; consults Export Controls Officer and advises faculty as needed.

Director, Research Integrity and Compliance (RIC)

Oversees the University's export controls compliance program.

Empowered Officials

The two Empowered Officials are the Vice President for Research and Innovation and the Associate Director, Export Controls and Research Security. Empowered Officials are authorized to (a) sign export license applications or other requests for approval on behalf of the University, (b) inquire into any aspect of a proposed export-controlled export or temporary import by the University, (c) verify the legality of any export-controlled transaction and the accuracy of information to be submitted, and (d) refuse to sign any export license application or other request for approval without prejudice or other adverse recourse.

Global Programs and Strategy Alliance (GPS Alliance)

As the central international office for the University system, works closely with campuses, colleges, units, faculty, staff, and students to support their international activities; maintains the International Travel Registry for faculty and staff; provides travelers with resources and advice related to University policy, insurance, health and safety, institutional relationships/supports abroad, etc.; encourages consultation with ECRS.

Internal/ External Sales Office

Manages the process for selling University goods and services to outside parties; assists ECRS in reviewing proposed international transactions for export control issues.

Office of the General Counsel (OGC)

In conjunction with the Director, RIC and ECRS, provides advice to University personnel regarding the laws, regulations, and University policies related to export controls.

Principal Investigator (PI)

The primary individual in charge of a research, public service, or instruction grant, cooperative agreement, contract, or other sponsored project. Works with SPA and ECRS to determine if their research is in a field that might be subject to export controls; works with sponsors to design a scope of work for performance at the University that remains within the fundamental research rule; for research projects with potential export control issues, works with ECRS, OGC, and sponsor to resolve these; if issues cannot be resolved and the PI believes a compelling reason exists for an exception from Administrative Policy: Openness in Research, prepares and submits a request for exception.

Sponsored Projects Administration (SPA) Grant and Contract Officers (GCOs)

Responsible for administering sponsored funds and monitoring compliance with the terms of the grant or contract. Identify potential export control terms in requests for proposals and related documents—including proposed restrictions on publication of research results and proposed use of sponsor export-controlled technical information—and communicate these to ECRS; take all other reasonable steps to comply with export control regulations; keep PIs informed about the status of negotiations.

Sponsored Projects Administration (SPA) Unfunded Research Agreements (UFRA) Staff

Negotiate material transfer agreements and confidentiality agreements when a PI desires to receive materials or confidential information that others want to transfer to campus; review proposed transactions for export control issues; consult with ECRS as appropriate.

Technology Commercialization (Tech Comm)

Negotiates material transfer agreements when a principal investigator wants to transfer materials off-campus and licenses to University intellectual property; assists ECRS in reviewing proposed international transactions for export control issues.

U Travel Program

Supports compliance with export controls by referring international travelers to the GPS Alliance site for registration and by providing appropriate links in its related policies.

Vice President for Research and Innovation

Provides educational opportunities for the University community; assists SPA and researchers in complying with export controls; makes the final decision whether to approve an award with export control restrictions per Administrative Policy: Openness in Research; serves as one of the University's two empowered officials.

Related Information

Board of Regents Policies

Administrative Policies

Other Related Information

History

Amended

March 2025 - Comprehensive review. Minor changes, largely for clarificaiton. Some irrelevant terms are eliminated. Changes are being proposed to make the policy easier to read, more coherent, and more relevant.

Amended

June 2019 - Comprehensive Review, Minor Revision. Minor wording changes and updates to links and contacts.

Amended

February 2015 - Comprehensive Review. Minor Revision. Provides greater specificity to the types of export-related activities or commitments in which employees may not engage. Clarifies regulatory terms and concepts. Reflects changes in responsibilities, especially for Empowered Individuals, the SVP for Research, Global Programs and Strategy Alliance, and (International Student and Support Services).

Amended

July 2012 -

  1. Codifies the processes and information that currently exists into an administrative policy and procedure.
  2. Specifies the University’s Empowered Official (per federal guidelines), and defines roles and responsibilities for the new position of Export Control Officer (ECO) and for units and individuals who interact with the ECO, and for units and individuals who are engaged in international travel or activities.
  3. Establishes the expectation of training for faculty, staff, and students who participate in activities subject to export controls.