Red Flags When Considering Export Control Laws
- Shipping equipment to a foreign country?
- Collaborating with foreign colleagues in foreign countries?
- Exposing foreign nationals to research labs?
- Training of students (foreign nationals on research protocols or equipment)?
- Working with a foreign country subject to US embargo?
- Sponsor approval rights over publication?
- Sponsor limit on participation of foreign students?
What is an export?
Any oral, written, electronic, or visual disclosure, shipment, transfer or transmission of any commodity, technology (information, technical data, assistance) or software code
• Outside the U.S. to anyone, including U.S. citizens,
• To a non-U.S. entity or individual, wherever they are located
What is export control and who oversees the federal regulations?
Federal regulations are promulgated and enforced by the Department of Commerce - Export Administration Regulations (EAR), Department of State - International Traffic in Arms Regulations (ITAR), and the Department of the Treasury - Office of Foreign Assets Control (OFAC).
Who is responsible for export compliance?
Each individual is responsible and held accountable for exporting information and items, within or outside of the US. Penalties for non-compliance are severe and can result in monetary fines, jail time, as well as termination.
What do I need to know?
It is important that Vanderbilt faculty and staff are aware of export controls and how they may affect their work. Please visit our website often for updated federal regulations, news, and training information. Export compliance is constantly evolving; expect changes in export controls. The constant change points to the importance of reviewing work and related information or items independently of previous or current work being conducted at Vanderbilt to understand whether or not it is controlled.
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