Export control laws support the national security, foreign policy, anti-terrorism and non-proliferation goals of the United States by imposing restrictions on the transfer of controlled items and information to certain countries and their nationals. The goal of UTC’s Export Control program is to support and sustain an open, unrestricted and collaborative research environment at UTC, while also ensuring that the UTC research community is informed and protected when export controls apply.
- Export Controls Regulations – what are they?
UTC adheres to all export controls regulations, including:
- International Traffic in Arms Regulations (ITAR) from the U.S. Department of State (Directorate of Defense Trade Controls), which cover military/defense items and services;
- Export Administration Regulations (EAR) from the U.S. Department of Commerce (Bureau of Industry and Security), which cover “dual use” items and technology designed for commercial purposes, but which could have military applications; and,
- Office of Foreign Assets Control (OFAC) from the U.S. Department of the Treasury, which covers restrictions due to foreign trade embargoes and economic sanctions.
These regulations determine how technology, technical data, technical assistance, and items or materials (from software to satellites and more) are physically or electronically exported, shipped, transmitted, transferred, or shared by the U.S. to or with foreign countries, persons, or entities.
UTC research may be subject to export controls oversight when:
- The items, materials, technology or technical data used in the research are identified on U.S. export control lists.
- Researchers work formally or informally with, or provide technical assistance to, foreign nationals from countries currently sanctioned (e.g., for trade, travel, or terrorism) by the U.S.
- A research agreement (e.g., contract, award, non-disclosure agreement) limits publication of results or participation in the design, conduct, or reporting of the research based on citizenship.
Some exports require express written permission from the United States government, known as an export license. Penalties associated with non-compliance with export controls can be severe, and may result in fines, jail time, loss of export privileges, loss of research contracts, and reputational damage to specific researchers and to UTC.
- What happens if Export Control laws are violated?
The consequences for noncompliance are very serious for both the University and the researcher. There can be monetary fines as well as prison sentences for certain offenses. To learn more, visit the Penalties page.
- Other Export Control Concerns
Export control conditions may impact related research activities, including
- International travel
- Overseas shipping
- Information technology
- Laptops & software
- Disposal of controlled items & information
For questions about any of these issues, contact UTC’s Office of Research Integrity at [email protected]. The Office of Research Integrity supports UTC researchers and research administrators in complying with export control regulations. Services provided include:
- Evaluating research activities (e.g., sponsored projects, technology transfers, international travel) for export control applicability and compliance requirements
- Assisting with the development of a Technology Control Plan (TCP) if export controls apply to a research activity or project
- Obtaining appropriate federal licenses and other approvals for an activity if it is export-controlled
- Advising on, and monitoring the completion of, required export compliance training
Additional Resources thanks to Cornell University.