Applicability
Export Control regulations affect a broad spectrum of university functions including, but not limited to, admissions, human resources, international programs, academic research, sponsored programs, technology transfer, accounts payable, materials management, and procurement. Export Controls affect Illinois State University in a variety of areas/activities including: research, travel outside the U.S., contracting, hiring, and shipping.
Means
An export or deemed export can occur through a variety of means, including:
- Shipping; the transfer of physical items outside of the U.S.
- Communication - Oral, written, or electronic communication (including emails);
- Access to controlled research, information, or other controlled items;
- Visual inspections of any Export Controlled items, software, or information by a foreign national, whether in the U.S. or abroad;
- Hiring and or collaboration with the University by foreign nationals; and
- Travel; entering another country with controlled items or information
Activities
All members of the Illinois State University community must consider whether Export Controls may apply before or when undertaking any of the following activities:
- Initiating any new research, including research in the following areas: unfunded, funded, under a grant, or contractual;
- Traveling for any purpose to or communicating by any means with a foreign national from a U.S.-sanctioned country, as listed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC);*
- Taking any electronic device that can store or communicate data, such as laptop computers, compact and portable storage devices, GPS systems, phones, mobile devices, and their associated software to another country;
- Taking any controlled items to another country;
- Exporting, releasing, transmitting, or allowing access to controlled research results;
- Participating in controlled research or training activities abroad;
- Allowing foreign persons, including but not limited to undergraduate or graduate assistants, colleagues, or other members of the public, to participate or have access to any controlled items, information or research activity;
- Taking receipt of controlled materials from a third party; or
- Making a purchase, applying for a grant, or entering into a contract that contains language that relates to Export Control provisions, including but not limited to publication restrictions, sponsor limitations on who may work on the research, Export Control compliance obligations, or Export Control reporting requirements.
*Not all persons born and/or raised in a U.S.-sanctioned country or other foreign country are subject to restrictions. Individuals with questions should contact the University's Export Control Officer