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 US 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 this website 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 Controlled Activities
In general, the export control regulations may cover, and require a license for, each of five main types of University activities:
- transfers of controlled information, including technical data, to persons and entities outside the United States (including US citizens in another country);
- shipment of controlled physical items, such as scientific equipment, that require export licenses from the United States to a foreign country;
- 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”);
- travel to certain sanctioned countries for purposes of teaching, presentation at conferences, or performing research; and
- 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.
Important: “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.