The purpose of the guidance on this page is to provide an overview of U.S. export control laws (including restricted parties and OFAC sanctions) in the context of University research security.<\/p>\n
Contact the University\u2019s Export Control Officer, Nicole Porter, at export@rochester.edu<\/a>\u00a0if you have any questions about export compliance. Researchers should also review the University\u2019s export compliance page<\/a> for more information.<\/p>\n <\/p>\n","protected":false},"excerpt":{"rendered":" The purpose of the guidance on this page is to provide an overview of U.S. export control laws (including restricted parties and OFAC sanctions) in the context of University research…<\/p>\n","protected":false},"author":76,"featured_media":0,"parent":3082,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":"","_members_access_role":[],"_members_access_error":""},"class_list":["post-8052","page","type-page","status-publish","hentry"],"acf":{"lead_in":"","display_title":"U.S. Export Compliance and Research Security","subtitle":"","call_to_action":"","hero_image_placement":"no_image","hero_media":"images","hero_pattern_option":"","hero_video":"","hero_image_landing":"","hero_image_landing_two":"","hero_image_landing_three":"","content_modules":[{"acf_fc_layout":"text","anchor":"","css_class":"","title":"What are U.S. export controls?<\/h2>","content":"U.S. export control laws restrict or regulate:\r\n
\r\n \t
Top tips for researchers<\/h2>","description":"","background_color":"#FFFFFF","width":"width-large","columns":"3","cards":[{"card_title":"","card_text":"Request restricted party screening prior to engaging with foreign parties<\/strong>, even in an informal research collaboration with a foreign institution or person.","card_background_color":"#f4f4f4","card_hover_color":"transparent","card_link":"","card_hover_arrow":"","card_image":"","card_image_size":"","card_image_placement":"","card_image_hover_state":"hover_fade","card_image_link":""},{"card_title":"","card_text":"Always check with the University\u2019s Export Control Officer<\/a> <\/strong>before engaging with a party in an OFAC sanctioned country or region.","card_background_color":"#f4f4f4","card_hover_color":"transparent","card_link":"","card_hover_arrow":"","card_image":"","card_image_size":"","card_image_placement":"","card_image_hover_state":"hover_fade","card_image_link":""},{"card_title":"","card_text":"Consider whether your foreign travel, or the hosting of an international visitor, could implicate export control laws<\/strong> and follow the steps described below.","card_background_color":"#f4f4f4","card_hover_color":"transparent","card_link":"","card_hover_arrow":"","card_image":"","card_image_size":"","card_image_placement":"","card_image_hover_state":"hover_fade","card_image_link":""}]},{"acf_fc_layout":"card_grid","anchor":"","css_class":"pb-45","title":"
Restricted party screening<\/h2>","description":"The U.S. Government implements, maintains, and enforces a wide range of restricted party lists that are relevant to University and faculty activities, and the University screens against these lists in a number of circumstances.\r\n\r\nAmong others, these lists include the Specially Designated Nationals List maintained by OFAC, the Entity List and Denied Persons List maintained by the Department of Commerce, and the Debarred Parties list maintained by the Department of State. Each restricted party list provides specific information on applicable restrictions.\r\n\r\nCertain research and educational activities that involve restricted parties may be prohibited or may require the University to first obtain a license before engaging in the activity. For example, the University or an individual may not export even low technology tangible items (or non-fundamental research technology or software) to an entity identified on the U.S. Department of Commerce\u2019s Entity List without first obtaining an export license.\r\n\r\nThe U.S. Government regularly updates restricted party lists, and sometimes new restricted party lists are created. In order to screen effectively, the University must review the most current information available on whether or not a party is subject to U.S. Government restrictions.","background_color":"#f4f4f4","width":"width-medium","columns":"1","cards":[{"card_title":"
Important note<\/h5>","card_text":"Various universities and research institutes in other countries appear on U.S. Government restricted party lists, and strict restrictions may be applicable to collaborations or activities with those entities.","card_background_color":"#FFFFFF","card_hover_color":"transparent","card_link":"","card_hover_arrow":"","card_image":"","card_image_size":"","card_image_placement":"","card_image_hover_state":"hover_fade","card_image_link":""}]},{"acf_fc_layout":"text","anchor":"","css_class":"pt-0","title":"","content":"The University recommends that restricted party screening be done prior to<\/em> engaging with foreign parties, including activities involving:\r\n
\r\n \t
OFAC sanctions<\/h2>","description":"The Office of Foreign Assets Control (OFAC) is part of the United States Department of the Treasury and administers several sanctions programs. OFAC sanctions can be either comprehensive or selective. For a complete list of the OFAC sanctions, please review OFAC Sanctions Programs and Country Information<\/a>.\r\n\r\nThe following are subject to comprehensive OFAC sanctions: Cuba, Iran, North Korea, Syria, and the following regions of Ukraine: Crimea, Donetsk, and Luhansk, and Russia*<\/strong>. Although OFAC sanctions against Russia are not considered comprehensive, they are evolving, which makes research collaborations with institutions or individuals in Russia particularly challenging.","background_color":"#FFFFFF","width":"width-medium","columns":"1","cards":[{"card_title":"
Important note<\/h5>","card_text":"OFAC sanctions may be applicable even if conducting fundamental research or engaging in activities involving published information. OFAC sanctions may be applicable even if no \u201cexport\u201d is taking place.","card_background_color":"#f4f4f4","card_hover_color":"transparent","card_link":"","card_hover_arrow":"","card_image":"","card_image_size":"","card_image_placement":"","card_image_hover_state":"hover_fade","card_image_link":""}]},{"acf_fc_layout":"text","anchor":"","css_class":"pt-0","title":"","content":"It is very important to contact the University\u2019s Export Control Officer<\/a> prior to any collaboration, appointment, or affiliation with a party in an OFAC sanctioned country or region, because OFAC sanctions can be very broad and restrictive.\r\n\r\nFor example, researchers should be aware that an OFAC license is likely required prior to conducting fundamental research in Iran or presenting published research results at a conference in Iran (even if done remotely).","background_color":"#ffffff","width":"width-medium"},{"acf_fc_layout":"text","anchor":"","css_class":"","title":"
Foreign travel<\/h2>","content":"Foreign travel is an export control risk because it may involve:\r\n
\r\n \t
International visitors<\/h2>","content":"International visitors to the University can be an export compliance risk. For example, visitors may themselves be or are associated with a restricted party, may be a citizen of a comprehensively sanctioned country, or may be engaging in research activity that is subject to export control laws.\r\n\r\nOffices within the Office of Global Engagement coordinate the application and onboarding process for all international visiting students<\/a>, including restricted party screening.\r\n\r\nFor visiting faculty and other researchers, departments and hosts should contact the International Services Office<\/a> early in the process to assist with obtaining the appropriate visa, or the Office of Global Engagement if there are questions regarding how the visitor should be categorized. For those individuals that the International Services Office assists in obtaining a visa, restricted party screening will occur during the onboarding process.\r\n\r\nThe Laboratory for Laser Energetics (LLE) follows visitor processes in compliance with Department of Energy requirements. Departments and hosts should contact LLE with any questions regarding international visitors to LLE.","background_color":"#ffffff","width":"width-medium"},{"acf_fc_layout":"accordion_new","anchor_id":"","classes":"","title":"
Overview of export compliance under the ITAR and EAR<\/h2>","description":"For purposes of research security, the primary U.S. export control laws to consider include:\r\n
\r\n \t
\r\n \t
\r\n \t
\r\n \t
\r\n \t