Office of Research: Research Compliance

The three principal export control regimes in the US are the International Traffic in Arms Regulations (ITAR) of the Department of State, the Export Control Administration Regulations (EAR) of the Commerce Department, and the regulations of the Office of Foreign Assets Control. All of these regulatory schemes are highly complicated. Compliance with ITAR and EAR requires an advanced understanding of the regulations, and the characteristics and capabilities of the equipment, biological and chemical materials, software code, computers, and other items, technologies and materials that are potentially subject to control. Institutions and individuals cannot avoid the application of export controls; they are the law regardless of whether an award or agreement cites their application. However, universities and their faculty may take steps to qualify much of their research for regulatory exclusions. However, they must strictly adhere to the prerequisites for exclusion.

If licensing is required, institutions and individuals must obtain licenses before exporting abroad to anyone, any controlled items and materials or related “technologies” or “technical data”, and must obtain licenses and institute security on campus to ensure that only appropriately licensed foreign nationals receive technologies or technical data concerning controlled items and materials on campus. Violations are subject to civil and criminal penalties that may be assessed against individuals as well as against institutions, and the loss of the privilege to export controlled items and materials abroad or to foreign nationals in the US. FSU’s policy, review process, certification requirements, and education, references, and links to the federal regulations are included below.