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Be aware of Export Controls !

Learn about export controls for research compliance, including what constitutes an export, deemed exports, fundamental research exceptions, relevant federal agencies, dual-use items, and when to be concerned about export controls in your research activities.

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Be aware of Export Controls !

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  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 • Fundamental research • 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 • 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: 617 496 7658 Global Support Services: Krister Anderson, krister_anderson@harvard.edu p.: 617 496 1702 https://www.globalsupport.harvard.edu/ Material Transfer Agreements (MTA), OTD http://otd.harvard.edu/faculty-inventors/resources/material-transfer-agreements/ Further Information: Office for the Vice Provost for Research: Export Controls http://vpr.harvard.edu/pages/export-controls-policies-and-procedures

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