Export Controls 
- Regulations & Resources -

Export controls may impose access, dissemination, and participation restrictions on information and tangible items; "exports" can include both the shipment of materials to another country AND/OR the disclosure of controlled information to foreign nationals who are here. Export controls may be promulgated by several federal agencies, including the US State Department, Commerce Department and Treasury Department (See " Regulations").

The conduct, products, and results of FUNDAMENTAL RESEARCH are generally EXCLUDED from federal "deemed export" controls - i.e., disclosure of information to foreign nationals on U.S. soil - in accordance with National Security Decision Directive 189 (AAU site).

The University of Vermont (UVM) relies on proper documentation in order to make use of exclusions and exemptions from licensing requirements. Recordkeeping is important if you are involved in research efforts where it may be necessary to:

1. ship research articles outside the U.S. or
2. share export-controlled information provided by third parties, such as vendors, subcontractors, or government collaborators; or
3. travel outside the United States for research or academic purposes.

           For information about what to consider when traveling abroad, click here.

A UVM Export License Decision Tree is available to assist you in determining the applicability of these regulations in the case of shipments outside US borders. Generally, the questions to ask when shipping something beyond US borders include:

• WHAT is being sent, and
• WHERE AND TO WHOM it is going.

Review the content of UVM's Export Controls Policy to ensure that you comply with "all" US export control laws and regulations.

Also, should you have any questions related to export controls, please contact Ruth Farrell, Associate VP for Research Administration.




Proceed to:   Decision Tree




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EXPORT CONTROL RESOURCES


• Information related to FUNDAMENTAL RESEARCH
  
  • National Security Decision Directive 189
    (Establishes "fundamental research exclusion")
    September 1, 1985
    
  • Reaffirmation of NSDD 189 by Condoleezza Rice
    November 1, 2001
    
• Guidance for those developing encryption code at UVM.
  
• A list of export control related definitions.



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EXPORT CONTROL REGULATIONS


• Federal export control regulations may be promulgated by:
 
• US State Department
      International Traffic in Arms Regulations   (ITAR)
     governing "defense articles and services"
     (predominately military items and information,
     including satellites and spacecraft)
  
• US Commerce Department
      Export Administration Regulations   (EAR)
     governing commodities, goods, and commercial information
     (primarily civilian)
  
• US Treasury Department
      Office of Foreign Assets Control (OFAC)
     administers and enforces trade embargos and sanctions
     See Lists of Sanctioned Countries and Specially Designated Individuals
  

Violations of these export control regulations can lead to significant civil and criminal penalties.


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OTHER FEDERAL AGENCY LINKS


• Bureau of Industry and Security, US Department of Commerce
  (see "Key Resources" list)
  
• Directorate of Defense Trade Controls, US Department of State
  (for ITAR and defense-related shipments)
  
• Office of Foreign Asset Controls, US Department of Treasury
  (economic and trade sanctions)
  
• Export Control Reference Materials on the Internet
  (Defense Technical Information Center web site)
  
• Bioterrorism Act of 2002
  (FDA site)

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"This material is adapted from the basic design and content of Stanford University's Decision Tree.  We appreciate Stanford in granting us permission to use its content for the benefit of the University of Vermont".

Last modified September 25 2009 10:48 AM