Export Controls

Export control laws regulate the transfer of controlled information (including technical data and technical assistance) as well as controlled physical items (such as scientific equipment) to foreign colleagues and organizations in the United States and abroad. Exports include the shipment or transfer of equipment, articles, services or encryption software to another country as well as the transfer of technical data or information to a foreign national, whether it occurs in the U.S. or abroad.

Boston University is committed to complying with all United States export control laws and regulations, including those implemented 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 Treasury Department through its Office of Foreign Assets Control (OFAC). In order to ensure compliance, researchers at Boston University must review the Export Control website of the Office of Research Compliance and related materials and carefully consider these issues in connection with every research project. Violation of export control laws and regulations can result in significant civil and criminal penalties for the University and for the individual researchers involved.

Export control laws prohibit the unlicensed export of certain commodities, technologies and information for reasons of national security or protection of trade.  Export controls usually arise for one or more of the following reasons:

• The nature of the export has actual or potential military applications or involves space-based research
• U.S. government concerns about the destination country, organization or individual
• U.S. government concerns about the declared or suspected end use or the end user of the export

U.S. Department of the Treasury Sanctions and other government programs prohibit individuals and organizations – including colleges and universities and their faculty and students – from providing services or support to some countries, political organizations and government-controlled organizations.  Violation of these sanctions programs may have serious consequences – including civil and criminal penalties – for the university and for the individuals involved.

Role of the Department or Unit

All Project Leads of global activities should review the Research Compliance Export Control website of the Office of Research Compliance to ensure compliance with export controls laws.

Those most affected will be researchers whose work involves equipment, technical software, or technical information in other media including presentations. Laptops and GPS devices may be restricted upon entrance to particular countries.

In particular, Project Leads should ensure that the following considerations are made or steps are followed:

• Before traveling abroad with a laptop or GPS equipment, complete the Laptop-GPS Checklist.
• Before initiating a program abroad that involves collaboration with or providing services or assistance to a foreign country or a government-controlled organization, review current U.S. Department of Treasury Sanctions Programs and the U.S. Department of State Country Policies and Embargoes.
• Before beginning any sponsored research project, researchers must complete the Research Project Export Control Checklist, which will alert OSP to potential issues.
• Before carrying, shipping or otherwise sending materials outside of the United States, travelers must consult the Shipments – Questions to Answer to determine whether an export license is required.
• Before traveling to countries that may be the subject of sanctions, or collaborating with a foreign national outside of Boston University or any person or entity outside of the United States, or presenting research at an international conference, check the following sanctions lists:
  • Dept. of Treasury Sanctioned Countries
  • Dept. of State Country Policies and Embargoes List
  • Consolidated Screening List
• If researchers expect that research may involve or be shared with any individual or entity on any of those lists, you must confer with OSP or OGC as appropriate to determine whether a license is required for planned activities.
• Always be alert to any “red flags” and if issues concerning publication or access restrictions, contact OSP or OGC as appropriate.

Role of Central Administration

More information about Compliance and Assistance with Export Control Laws is available at the Office of Research Compliance website, including support material like the Research Project Export Control Checklists. Further details, Q&A and checklists on business travel to restricted countries, travel with a laptop or GPS, transport of materials abroad, FAQs, and “red flags” for researchers are also on these pages.