Export Control Compliance at The University of Arizona

UA Policy Statement

It is the policy of The University of Arizona that research, instruction, and public service will be accomplished openly and without prohibitions on the publication and dissemination of the results of academic and research activities to the fullest extent permitted by law. However, while research in a university setting generally is, and normally can be conducted openly and without restrictions, we recognize that there are certain conditions under which the export of information or technology is either prohibited by law, or requires a license from the U.S. Government. Thus, it is also the policy of The University of Arizona to comply with all United States export control laws and regulations, including those implemented by the Department of Commerce (DoC) through its Export Administration Regulations (EAR), by the Department of State (DoS) through its International Traffic in Arms Regulations (ITAR), and embargo regulations imposed by the U.S. Treasury Department through its Office of Foreign Assets Control (OFAC).

Overview of Export Control Laws

Federal export control laws and regulations restrict the overseas shipping, transmission or transfer of certain categories of information, technologies and items to anyone,including certain U.S. citizens. In addition, these laws and regulations also restrict "deemed exports" -- i.e., the transfer or communication of restricted technologies or information to "foreign persons or entities" within the United States (other than full-time university employees with U.S. permanent resident (green card) status, or who are political asylees). The deemed export of information includes, but is not limited to, lectures,seminars,presentations and publications. In addition, export control laws restrict the shipping, transmission or transfer of articles or information to certain prohibited persons, entities and countries. Export control laws also apply to university property (such as laptop computers and PDAs, and the software installed on such equipment) taken outside the United States.  

Review the University of Arizona Export Compliance Manual

1.  
   1. prior to commencing any research, to review and cooperate with OVPR to determine whether any technical information or technology involved in their research is subject to the export control law or regulations and if so, whether any exclusion is available under the export control regulations;
   2. to re-evaluate that determination before changing the scope or adding new staff to the project to determine if such changes alter the initial determination;
   3. to make export determinations far enough in advance to obtain an export license from the appropriate agency, if required and available; and,
   4. to ensure that foreign nationals are excluded from access to restricted data or technology until the availability of an exclusion has been determined, or an export license has been obtained.

The University will assist PI's in assessing the application of such regulations, but primary compliance responsibility rests with the principal investigator of the research. Please refer to the Export Control resources (Processes, Tools, Websites, & Training). Dr. Leslie P. Tolbert, Vice President for Research, Graduate Studies, and Economic Development is the University Empowered Official for Export Control. Questions regarding export control requirements should be referred to Nora Moriarty, Export Control Officer, njm1@email.arizona.edu, (520) 626-2437.