Training

Export controls can be very complicated and determining if and when your activity or research may require an export license is not easy. The Office of Research Integrity has several training materials to assist university personnel in learning about and complying with U.S. export control regulations.

CITI Export Control Training

Individuals seeking training in export control regulations as they relate to University research may access the U.S. Export Control Regulation web-based program on the CITI website. These courses contain several modules that provide comprehensive information on export controls and details on each set of government regulations. There are specific modules for different personnel involved in export controls such as researchers, administrators, shipping, international collaborations and purchasing. Please follow these step-by-step instructions to sign up for the CITI course on export controls: These modules consist of the following:

Export Compliance for Administrators

Provides an overview of export controls, which are an ever-growing area of compliance for universities and research institutions across the United States and around the world. Export control laws and regulations affect a variety of activities, including many activities that take place physically within the U.S. An overview of the three primary U.S. regulatory agencies and their differences is also provided. It includes an in-depth discussion to help learners recognize when export controls may be applicable to various research activities.

Provides an overview of export compliance concepts for research administrators. It discusses the difference between fundamental and proprietary research, as well as prohibited parties and embargoed/sanctioned countries. Included are concerns that may exist when working with individuals subject to export control regulations, basic concepts associated with foreign nationals partaking in research projects on campus, and why the project’s location is essential for compliance with export control regulations.

Explores the key concepts and export compliance risks for employees of operational departments. It discusses the different types of organizational activities, common export compliance risks on campus, and export compliance checkpoints and risks to operational departments.

Provides an understanding of collaborations, which are a significant element of many research enterprises. It offers an overview of the types of collaborations in which institutions of higher education involve themselves today, and how they can intersect with export and sanctions regulations. Additionally, it discusses topics such as traditional types of collaborations, regulatory safe havens, challenges presented by the global market, and types of risk mitigation for at-risk international collaborations.

Provides an overview of concepts for international shipping of export-controlled items from the United States to international locations. Basic terms used in international shipping are defined as well as an overview of the concepts of “know your customer” and “be familiar with your customer,” the U.S. Department of Treasury’s role in international shipping, steps an organization should take prior to exporting, and different shipping solutions.

Presents issues ranging from vetting the vendor (vendorization) to procurement and identifying risks that are associated with various activities taking place, typically, within the purchasing/finance department. It also discusses classification numbers, Office of Foreign Assets Control (OFAC) regulations, and restricted party screening (RPS).

Provides an overview of how export controls affect distance education. It discusses when export controls affect distance education and learning, and how distance education is restricted by geographic location.

 
Export Compliance for Researchers

Provides an overview of export controls, which are an ever-growing area of compliance for universities and research institutions across the United States and around the world. Export control laws and regulations affect a variety of activities, including many activities that take place physically within the U.S. An overview of the three primary U.S. regulatory agencies and their differences is also provided. It includes an in-depth discussion to help learners recognize when export controls may be applicable to various research activities.

Focuses on university activities that are subject to U.S. sanctions programs. It also identifies university activities that may require a general or specific license under Office of Foreign Assets Control (OFAC) sanctions, the scope of some of the general licenses and exemptions available under U.S. sanctions programs, and available OFAC resources and how to apply for a license.

Provides an overview of how export controls may affect technology used in research. It discusses the specific technology that may be restricted, classifications and exclusions, and appropriate methods for complying with the restrictions.

Offers a review of how researchers can responsibly conduct export-controlled research activities, conveys accumulated best practices commonly accepted by the university export control community, and provides other useful information in complying with U.S. export control laws and regulations.

Expands on the impact of the export control regulations on the researcher and research activities. It discusses the export control concerns associated with the input, conduct, and output of research activities; the responsibilities and best practices employed by researchers engaging in activities subject to export controls; and the security measures typically implemented by researchers to protect export-controlled research programs and activities.
Provides an understanding of collaborations, which are a significant element of many research enterprises. It offers an overview of the types of collaborations in which institutions of higher education involve themselves today, and how they can intersect with export and sanctions regulations. Additionally, it discusses topics such as traditional types of collaborations, regulatory safe havens, challenges presented by the global market, and types of risk mitigation for at-risk international collaborations.
Identifies export-controlled biological material, technology, technical data, and equipment. It discusses export control implications of life science research involving biological material and biomedical applications, differentiations between export control regulations, and how dual use research of concern interconnects with the regulations.
Presents issues ranging from vetting the vendor (vendorization) to procurement and identifying risks that are associated with various activities taking place, typically, within the purchasing/finance department. It also discusses classification numbers, Office of Foreign Assets Control (OFAC) regulations, and restricted party screening (RPS).
Provides an overview of concepts for international shipping of export-controlled items from the United States to international locations. Basic terms used in international shipping are defined as well as an overview of the concepts of “know your customer” and “be familiar with your customer,” the U.S. Department of Treasury’s role in international shipping, steps an organization should take prior to exporting, and different shipping solutions.
 
Export Compliance for Sikuliaq

Provides an overview of export controls, which are an ever-growing area of compliance for universities and research institutions across the United States and around the world. Export control laws and regulations affect a variety of activities, including many activities that take place physically within the U.S. An overview of the three primary U.S. regulatory agencies and their differences is also provided. It includes an in-depth discussion to help learners recognize when export controls may be applicable to various research activities.

Provides a basic understanding of U.S. export control laws and regulations as they affect research conducted outside of U.S. territorial waters. It identifies when items controlled under the export control regulations are considered exported from the U.S., when an item may require an export license, issues that may affect research being conducted in foreign waters, and when license exceptions may be applicable.

Provides an overview of how export controls may affect technology used in research. It discusses the specific technology that may be restricted, classifications and exclusions, and appropriate methods for complying with the restrictions.

Provides an overview of concepts for international shipping of export-controlled items from the United States to international locations. Basic terms used in international shipping are defined as well as an overview of the concepts of “know your customer” and “be familiar with your customer,” the U.S. Department of Treasury’s role in international shipping, steps an organization should take prior to exporting, and different shipping solutions.

Provides an understanding of collaborations, which are a significant element of many research enterprises. It offers an overview of the types of collaborations in which institutions of higher education involve themselves today, and how they can intersect with export and sanctions regulations. Additionally, it discusses topics such as traditional types of collaborations, regulatory safe havens, challenges presented by the global market, and types of risk mitigation for at-risk international collaborations.

Presents issues ranging from vetting the vendor (vendorization) to procurement and identifying risks that are associated with various activities taking place, typically, within the purchasing/finance department. It also discusses classification numbers, Office of Foreign Assets Control (OFAC) regulations, and restricted party screening (RPS).

 
Additional Export Compliance Training

The impact of undue foreign influence in research, particularly at universities, remains a concern for U.S. federal officials and university administrators. This course provides university faculty, students, and others involved in international engagement with a concise overview of the risks and mitigations associated with undue foreign influence.

Learners will begin by reviewing the key concepts related to claims of undue foreign influence on the U.S. academic and research environment, including the publicly voiced concerns of federal funding agencies, federal law enforcement, and Congress. They will then learn about how undue foreign influence conflicts with the principles of research integrity, as well as the reporting requirements, U.S. government actions, and effective university practices that address undue foreign influence.

In addition to the training materials provided by the university, there are a number of external resources available to you that can provide additional information regarding export controls:

The U.S. Bureau of Industry and Security (BIS) has created on-line training modules covering export controls, deemed exports, performing export control classifications, license exceptions, and anti-boycott regulations. The training modules are broken up into short video segments that provide general information on the essentials of export control in a very accessible and user-friendly format. The on-line training can be found at BIS On-line Training Room.

In 2004, the Council on Government Relations (COGR) created the brochure “Export Controls and Universities: Information and Case Studies (PDF)". The brochure provides general information regarding export controls and their impact on academic research. Included in the brochure are a number of case studies that represent potential situations encountered by universities.