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Working with the Export Control Office

Last updated on March 5, 2025 11 min read Export Control - Working with the Export Control Office

Violation of export control laws can result in significant civil and criminal penalties for the University and for the individual researchers involved. We encourage researchers to contact the Export Control office early to ensure compliance with export control law.

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Do I need to work with the Export Control office?

Most research activities at BU are excluded from export controls because they fall under the fundamental research exclusion. Fundamental research is unrestricted research that is published and shared broadly within the scientific community. For example, university-based research on vectors for salmonella typhi that is published broadly is considered fundamental research and uncontrolled.

Research is not considered fundamental when there are restrictions placed on the outcome of the research or restrictions on methods used during the research. This includes proprietary research; industrial development; design, productions and product utilizations the results of which are restricted; or government-funded research that specifically restricts the outcome for national security reasons.

Export Control Checklist

Determining if your project may be subject to export control laws is an essential first step before sharing information or physical items with collaborators and organizations outside of the United States. The checklist below helps researchers determine if export controls apply to their project and should be reviewed at the proposal development stage so the Export Control team can better assist with the unique export control compliance protocol once funding is granted.

  • Does your research involve development or use of any data, hardware, materials, technology, software or services listed on the US Munitions List or the Commerce Control List?
  • Are you developing or using encrypted software in which you will have access to the applicable source code?
  • Were you asked by the sponsor to provide the nationalities/citizenship status of the researchers working on this research (excluding training grants, fellowships and career development awards)?
  • Are you aware of restrictions on publication of the results of your research or pre-publication review & approval by the sponsor?
  • Are you planning to ship or take any of the following abroad?
    • Material(s)
    • Prototype(s)
    • Samples (including biological/hazardous materials)
    • Equipment
    • Hardware
    • Technology
    • Software
    • Technical drawings
    • Schematics
    • Data
  • Are you planning to work with institutions or companies located abroad?
  • Do you anticipate receipt of proprietary information subject to a non-disclosure agreement?
  • Do you plan to travel to a destination on the sanctioned programs and countries list?
  • Are any participants (scholars, students, companies, universities) on the denied persons lists?

If you answered “yes” to one or more of these questions…

Please contact our office, as your project is likely subject to export control laws. In your email, please provide as much detail as possible about each “yes” answer.

If applicable, please provide the US Munitions List category and detail and Commerce Control List classification number. It’s ok if you’re not 100 percent confident; once you’re in touch with our office, we will help confirm your classification.

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Starter Guidance for Various Scenarios

In this section, researchers will find guidance, forms, and information about several export control scenarios. This guidance is intended as a starting point only. If any of the scenarios below pertain to you, please contact the Export Control office as soon as possible so we can help you navigate the specifics of your situation.

Before Beginning a Sponsored Research Project

Before beginning any sponsored research project, you must complete the Export Control Checklist in the Proposal Summary Form, which will alert Sponsored Programs to potential issues.

If you’re submitting to NASA you’ll need the NASA Restrictions on Funding Activity with China form.

Work on Controlled Research

Principal investigators working on controlled research are required to develop a Technology Control Plan, which includes the forms. You are only required to complete the necessary forms, and the University Export Control Officer is able to help determine these requirements:

Unsolicited Requests

Faculty members often receive unsolicited emails or phone calls from students, researchers, or companies from outside of Boston University to discuss collaboration, research results, publications etc. Conduct due diligence in communicating with individuals that you don’t know and cannot easily verify their credentials.

You should always screen all requests for assistance or collaboration to ensure that these are legitimate requests, especially if these are related to controlled research, equipment, technologies or data, or unpublished results of your research.

You may meet other researchers at meetings, conferences, seminars, or other professional or social events or you may simply receive a phone call, email, or a visit from someone that you don’t know. Sharing too much information about your research could not only jeopardize your research efforts, it could also violate export regulations.

Consider some of the questions below before you engage in collaboration or provide assistance to researchers you don’t know.

  • Does the request come from a researcher at a known university/institution?
  • Does the university/institution have a website?
  • Does the researcher use an organizational email or did he/she use a private email?
  • Does the researcher have a website where you can verify his/her area of expertise?
  • Is the request consistent with his/her area of expertise?
  • Does the researcher have sufficient level of scientific expertise for the questions asked?
  • Did you call the individual and his department head to verify his/her affiliation with particular institution?
  • Is the request consistent with the type of questions/requests that you would receive from your colleagues at other US institutions?
  • Did you try to locate information about this individual online?
  • Have any of your colleagues ever met/collaborated with the individual?
  • Are there any papers that he/she published in scientific journals?
  • Is he or she asking questions related to your “unpublished” research, security procedures at your Center/Lab, or whether you work on military/space or controlled technology or research?
  • Did you screen the foreign researcher against all of the “Restricted Party Lists?”

Traveling Abroad

Overview

Note that travel abroad with technical data, technology, software, or information controlled for United States (US) export purposes is prohibited, and you will need a license or documentation of an exemption prior to the travel.

Travel to Sanctioned Countries

If you plan to travel to any of the countries that are the subject of US Sanctions to conduct University-related work or research or to present the results of University-related work or research, you should consult with the University Export Control Officer (henceforth Export Control Officer) to determine whether any restrictions will apply to your travel. If a license is required, the Export Control Officer can assist with that effort.

Licenses are required for many activities in the following countries: Cuba, Iran, Sudan, Syria, and North Korea. If you plan to travel to any of these countries, contact the Export Control Officer.

Laptops and GPS

Principal investigators traveling abroad should request the GPS/Laptop Checklist from the Export Control office and keep it on file for five years after the trip.

Take the completed form with you when you travel in case you are asked by US Customs officials what type of information is on your laptop and which license exception you are applying for the equipment/devices.

In addition, the Export Control Officer will assist with securing a “clean” laptop for travel.

You are prohibited from taking any export controlled materials/papers/reports on your laptop outside of the US without an export license or valid license exception that is determined by the Export Control Officer. Please pay special attention to the reports that you are submitting to your project managers and instructions that you are receiving from sponsor agencies, which can be part of the Department of Defense, Department of Homeland Security, Department of Energy, NASA, or NOAA. Even if your research qualifies under the Fundamental Research Exclusion; these materials may be controlled for export purposes and not intended for public release. Contact the Export Control Officer to assess whether or not you may take these abroad.

The National Counterintelligence and Security Center has tips for traveling overseas with mobile phones, laptops, PDAs, and other electronic devices.

Shipments/Transports Outside the US

Principal Investigators/Lab Managers are strongly encouraged to use the Denied Party Screening Form and refer to the Export Control Manual when shipping abroad.

You are welcome to use your own process to document export control decisions. Keep in mind that you are required to keep shipping records on file for five years after the shipment is made or later if shipping under an export license. The Export Control Officer is available to assist with international shipping requirements.

Any member of Boston University interested in shipping ITAR controlled items, software, and/or data abroad should contact the Export Control Officer for assistance prior to the shipment.

Before you carry, ship, or otherwise transport materials or equipment outside of the United States, you should:

  • Determine if the commodity requires an export license and assist the University in securing the license, when required. It can take several months to obtain a license. Guidance and assistance in making this determination and applying for a license are provided below.
  • Consult with the University’s customs broker to ensure that your shipment abroad meets other legal requirements. Details about the University’s customs broker and their services are available from Sourcing & Procurement.

Shipment/Transport Questions to Answer

To determine the applicability of export licensing requirements, you should review the following steps. If, after this review, you have any questions, please contact the Export Control Officer. It is important to clearly identify what you are exporting, to whom you are exporting it, and the purpose for which it will be used.

1. What is it?

You should review the Commerce Department’s Commerce Control List (CCL) and the Department of State’s Munitions List (USML) to determine whether the item(s) you intend to ship are subject to export restrictions. Always check with the manufacturer of any item(s) you intend to ship to determine the proper classification.

If the item you intend to ship appears on either list, you may need a license.

2. Where is it going?

The country of the item(s) final destination determines the licensing requirements. Even if the item(s) you intend to ship are not on the CCL or USML, you may be prohibited from sending certain items to certain countries that are the subject of sanctions or embargoes, including the Western Balkans region, Burma, Côte D’Ivoire, Cuba, Democratic Republic of the Congo, Iran, Iraq, Former Liberian Regime of Charles Taylor, North Korea, Sudan, Syria, and Zimbabwe. You can check the current lists of all sanctioned or embargoed countries at:

If you are shipping to a sanctioned country, you may need a license.

3. Who will receive it?

The final recipient of your item(s) cannot be on any of the lists of individuals or entities prohibited from receiving certain exports. The United States publishes several lists of individuals and entities that are prohibited from receiving certain types of goods, including the Denied Persons List, the Unverified List, the Specially Designated Nationals List, the Entity List, and the Debarred Lists. Check each of these lists before proceeding with your purchase. Each list is available online in searchable form at Export.gov.

If the intended recipient of your shipment appears on one of these lists, contact the Export Control Officer.

4. What will they do with it?

The end-use of your item(s) cannot be subject to the EAR’s general end-use prohibitions. If the materials, equipment, or technology are designed or adapted for a military application, or may be used in connection with or relate to the proliferation of weapons of mass destruction or terrorism, it is unlikely that you will be able to ship or transport those materials abroad.

If the end-use of your item(s) may be prohibited, contact the Export Control Officer.

5. Red flags

Check the Department of Commerce Red Flag list to identify possible violations of export control laws.

If any of these red flags apply, contact the Export Control Officer.

Note regarding Materials Transfer Agreements (MTAs): The Technology Development office generally processes requests to transfer research materials from Boston University to researchers, academic institutions, or other third-parties and uses standard forms and agreements to do so. If you intend to transfer research materials to a researcher, academic institution, or other third-party outside of the United States you must complete Technology Development’s Export of Materials Checklist before your request may be processed. If you think the materials you will be transferring may be subject to export controls, please inform Office of Technology Development at the time of request.

You must also secure license approval or verify license exception prior to shipment for all export-controlled items. Contact the Export Control Officer for guidance on verifying license exceptions and assistance for the submission of license applications, if required.

When to Contact the Export Control Office, Determination Tree


*Review the USML and the CCL.

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