1. Be aware of Export Controls!
April 21,2017
Katrin Duevel
Research Compliance Officer

2. Exports
Exports - Any item that is sent from the US to a foreign destination or a foreign national is an export
Deemed Exports - Any release of technology or information subject to the export regulations to a foreign national while inside the U.S. (i.e., on campus) is deemed to be an export to the home country of the foreign national.
Does not apply to foreigners with:
A permanent residence (“Green Card”)
U.S. citizenship
Status as a “protected person”

3. Export Control Questions
What is being exported?
Where to? (country/institution/individual)
What for? (Purpose)
When?

4. Federal Agencies US Department of State
International Traffic in Arms Regulation (ITAR)
US Munitions List (USML)
US Department of Commerce, Bureau of Industry and Security (BIS)
Export Administration Regulation (EAR)
Commerce Control list (CCL)
Examples for “dual use” items:
Chemicals, microorganism, toxins,
software, sensors, electronics, lasers, drones….

5. Federal Agencies (cont.)
US Department of Treasury
Office of Foreign Assets Controls (OFAC)
Economic and trade sanctions
Specially Designated Nationals list (SDN), individuals, groups and entities

6. Fundamental Research Exception
Research in science, engineering and mathematics the results of which ordinarily are published and shared broadly within the research community
Not considered fundamental research
Restrictions placed on the dissemination of research results
Restrictions on methods used during the research
Proprietary research, industrial development, design, production, and product utilization
Harvard does not accept sponsor restrictions on publication of research results.

7. When should you be concerned about export controls?
Using export-controlled technology in your lab
Shipping items, software or information internationally
(Tip: ship directly from vendor)
Teaching courses abroad or online
Foreign travel
International collaborations or partnerships
Paying someone in another country for items or services
It is very important to know who you’re dealing with and to have your export control officer perform a “Restricted Party Screening”.

8. Heads Up Export control questions in GMAS More outreach and training
Alerts Export Control Administrator
Possible GMAS approval function
More outreach and training
(CITI training now available)

9. Reach out! FAS/SEAS: Katrin Duevel, Kduevel@fas.harvard.edu,p:
Global Support Services: Krister Anderson,
p.:
Material Transfer Agreements (MTA), OTD
Further Information:
Office for the Vice Provost for Research: Export Controls