Export Controlled Activities

In general, the export control regulations may cover, and require a license for, each of five main types of University activities:

1. transfers of controlled information, including technical data, to persons and entities outside the United States (including U.S. citizens in another country);
2. shipment of controlled physical items, such as scientific equipment, that require export licenses from the United States to a foreign country;
3. verbal, written, electronic, or visual disclosures of controlled scientific and technical information related to export controlled items to foreign nationals, even when it occurs within the United States (“deemed exports”);
4. travel to certain sanctioned countries for purposes of teaching, presentation at conferences, or performing research; and
5. the provision of defense services.

These covered activities include the transfer of controlled information or physical items to individuals or entities that are identified on any of the “Lists to Check,” as explained in more detail in Compliance and Assistance with Export Controls. “Deemed exports” (#3 above) are of particular concern in a University community. Unless exclusion applies, a “deemed export” license may be required before information is conveyed (even visually through observation) to foreign students, researchers, staff, or visitors on campus.