Provost’s Export Control Policy Statement

Boston University Office of the Provost
Professor Jean Morrison, University Provost and Chief Academic Officer

One Silber Way
Boston, Massachusetts 02215
T 617-353-2230 F 617-353-6580

TO: Deans, Department Chairs, Laboratory & Center Directors, and Administrators

FROM: Jean Morrison, University Provost

DATE: July 2022

SUBJECT: Export Policy Statement

Boston University conducts focused research to advance knowledge, enhance  student learning experiences, and build its reputation in the scientific and  technical communities while providing positive returns on sponsoring partners’  investments. While Boston University endorses the principles of freedom of  inquiry and open exchange of knowledge, we must be mindful of the federal  laws and regulations governing the exchange of research materials and  results that are subject to export controls.

The export of certain technologies, software, and hardware is regulated and  controlled by Federal law for reasons of national security, foreign policy,  prevention of the spread of weapons of mass destruction, and for competitive  trade reasons.

Boston University and all its faculty, students and employees are required to  comply with the laws and implementing regulations issued 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 Department of the Treasury through its Office of Foreign  Assets Control (OFAC) and other applicable regulations. Export regulations  apply regardless of the source of funding, both external and internal.

While most research conducted on our campuses is excluded from these  regulations under the Fundamental Research Exclusion, university research  involving specified technologies controlled under the EAR and/or ITAR, or  transactions and exchanges with designated countries, individuals, and  entities may require Boston University to obtain prior approval from the  appropriate agency before allowing international students and scholars to  participate in controlled research, collaborating with a foreign company and/or  sharing research—verbally or in writing—with persons who are not United  States citizens or permanent residents. The consequences of violating these  regulations can be severe, ranging from loss of research contracts and

exporting privileges to monetary penalties and jail time for the individual  violating these regulations

The export control regulations affect not only research conducted on campus,  but also travel and shipping items abroad. Simply traveling to certain  sanctioned countries could require a license from OFAC. As a result, this  policy is applicable to all departments of the University. OFAC sanctions  prohibit transactions and exchange of goods and services in certain countries  and with designated persons and entities. Multiple lists of denied individuals  and parties are maintained and enforced by federal agencies including the  Departments of State, Commerce, and the Department of Treasury. Shipping  items/data outside the U.S. as well as taking items or data on a flight, even if  shipping or traveling in the conduct of research, could require a license from  these agencies.

While Boston University is committed to export controls compliance, it also  recognizes the complex nature of export control laws. Therefore we strongly  encourage you to contact the University Export Control Office if you are  planning to export materials/data abroad, to engage in controlled research,  work with a university or company abroad, have persons who are not United States citizens or permanent residents working on your research (including  students, post docs, etc.), travel internationally, or if you have any questions  related to export controls and the projects in which you are currently involved.

You can find more information and resources on the Export Control website.

We ask each of you to take this matter very seriously and to support us in this  effort. Any member of the BU community having any questions concerning  this policy, its application to a specific situation, or suspecting violations of  U.S. export controls should contact the Export Control Office, the Associate  Vice President for Research Compliance or the Office of the General Counsel. Concerns may also be reported through the BU Ethics and Compliance  Hotline.

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