Export Control regulations are a set of federal regulations that were promulgated to protect both the economic interests and the national security of the United States against unauthorized export of certain technical data and equipment.
These are enforced by several federal agencies: the Department of Commerce, through its Export Control Administration (EAR), the Department of State through its International Traffic in Arms Regulations (ITAR national security) and the Department of Treasury’s Office of Foreign Asset Control. While the US government has repeatedly protected the dissemination of federally-funded “fundamental research”, it may restrict technical data, equipment and work in certain sanctioned countries under these regulations. Fundamental research as identified under NSDD-189 means “ basic and applied research in science and engineering which ordinarily are published and shared broadly within the scientific community as distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reason.”
These regulations could impact some U. of Chicago research, and the University is required by the federal government to have a compliance program in place to assure that faculty are aware of the regulations and to provide assistance in meeting those requirements. In practice, these rules have a direct impact on what hardware, laboratory equipment, materials, software, technology and technical data that we, as a responsible institution, can export out of the country by any means. In certain cases, they also restrict access by individuals working in and visiting our research laboratories. These regulations also potentially affect what institutional research partners we work with during the course of our U.S.-based and international collaborations; how we disseminate research results and to whom; and travel abroad for teaching and research purposes. Export controls affect all scientific disciplines (regardless of whether the activity concerns sponsored or non-sponsored research) as well as business and service transactions with restricted countries and restricted end users.
At the University of Chicago, we are committed to maintaining an open teaching and research environment that supports the global benefit of our academic and research endeavors. However, we must also comply with federal regulations and fulfill our specific responsibilities under the regulations. In recent years, U.S. Government agencies have strictly enforced these regulations as applicable to universities and research institutions, resulting in numerous investigations as well as civil and criminal sanctions at the institutional and individual levels.
Toward this objective, we are enhancing our export control compliance program on several key fronts, including providing additional resources to better enable our community to comply; user-friendly export procedures; awareness training; and enhanced website guidance. As with all areas of research compliance, we strongly encourage taking advantage of these resources, beginning with reading the Export Control Overview and Frequently Asked Questions and Answers. These documents explain how export controls specifically affect research and other export-defined activities, as well as the University’s requirements. Our website also identifies a new set of export control processes and a current list of who to contact for assistance in these matters. Most important: Do not hesitate to seek guidance on an export control matter. If you become aware of a potential export control problem, report it immediately to one of the designated individuals listed on the contacts page. On behalf of the University of Chicago leadership, thank you in advance for taking the time to understand and comply with these obligations.