Export Management

The U.S. has complex export control laws and regulations which are scattered throughout the U.S. Code (USC) and the Code of Federal Regulations (CFR). In keeping with the diversity of export regulations, a number of federal agencies have been given export oversight responsibilities. Links to the export regulations most likely to apply to university research programs are available on the Federal Regulations page. The following list of U.S. Goverment Agencies with export control responsibilities, while not exhaustive, is intended to provide some indication of the scope and complexity of export management issues that might arise related to the conduct of university activities:

  • Bureau of Industry & Security, Department of Commerce
    • Commercial Items & Dual-Use Technology - Examples:  Global Positioning System (GPS), Night Vision equipment, encryption technology, senors, lasers, navigation systems, avionics, satellite technology, software, some infectious agents & toxins, and nuclear technology.
    • Deemed Exports of Technical Data
  • Directorate of Defense Trade Controls, Department of State
    • Defense Articles - Examples:  technology, software and technical data related to encryption/decryption, satellites, missiles/rockets, sensors, arms, and explosives.
    • Defense Services
    • Deemed Exports of Technical Data
  • Office of Foreign Assets Control
    • All Transactions, but predominantly financial in nature
    • Travel Restrictions
  • Drug Enforcement Agency, Department of Justice
    • Controlled Substances (Drugs)
    • Chemicals and Precursors
  • Food and Drug Administration
    • Drugs (not on the DEA controlled substances schedules)
    • Medical Devices
    • Biologics
    • Investigational Drugs & Medical Devices
  • Fish & Wildlife Service, Department of the Interior
  • Nuclear Regulatory Commission
    • Nuclear Materials
    • Nuclear Equipment
  • Centers for Disease Control and Prevention (CDC)
    • Infectious Agents
    • Biological Toxins
  • Department of Energy
    • Natural Gas
    • Electrical Power
    • Nuclear Technology
  • National Marine Fisheries Service, National Oceanic and Atmospheric Association, Department of Commerce
    • Marine Mammals
    • Endangered Species
  • Animal and Plant Health Inspection Service, Department of Agriculture
    • Import & Export
    • Live Animals, tissues and animal products
    • Infectious Agents
    • Plants, seeds, tubers, plant products, etc.
    • Soils

Each agency has it's own regulations regarding permitting or licensing, including who may apply.  BIS, DDTC and OFAC require that institutions register and that license requests are made by designated individuals on behalf of the organization.  The UAF Office of Research Integrity is responsible for assisting university members in evaluating the need for licensure, screening parties to the export, preparing and submitting license requests to these agencies.  Other agencies issue permits or licenses to individuals rather than organizations.  The UAF Office of Research Integrity will provide guidance to university personnel on the need for licenses or permits, licensing forms, processes, and timelines.

UAF Export Management Policy identifies the duties and responsibilities of university personnel and offices related to export management.