Frequently Asked Questions

General FAQs

What are “Export Controls?”
The term “export controls” refers to regulations ad­ministered by three different federal agencies that set restrictions on the types of information and technol­ogy that can be shared with (i.e., “exported” to) for­eign nationals and shipment of controlled physical items such as scientific equipment.

Who controls exports?
The Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) are the bodies of regulations most likely to affect re­search institutions. The Office of Foreign Assets Con­trol (OFAC) regulations can also affect many of the activities and financial transactions that take place in an academic institution as well.

Why are certain exports controlled?
Examples of why certain items, software, technology and services are controlled include: national security, proliferation of chemical and biological weapons, nuclear proliferation, anti-terrorism, crime control and regional stability.

How do these regulations apply to University activities?
The export control laws have existed since the 1940s but have had increased attention since September 11. Most University activities fall under exemptions, such as the “fundamental research” exemption, the “public domain” exemption and the “teaching” ex­emption. Other activities, such as taking a laptop out of the country, certain interactions with foreign nationals or shipping controlled items may require licenses or special exclusions. In addition, if a re­searcher accepts a clause on a contract that restricts how the results can be distributed or who can work on the project, export control regulations may also apply.

What happens if we do nothing?
Educating our faculty and staff is the best protec­tion against violations. Penalties for violations can be more than $1,000,000 and/or imprisonment of up to 20 years. These are assessed against the individual, and the University could be penalized as well by being barred from accepting federal funding.

Where can I go to get more information on export controls?
The Office of Resource Management, Operations and Emergency Preparedness (RMOEP) in the Medical Center has been delegated University-wide authority in this area.  You can email your questions to: exportcontrol@gwumc.edu.