Export Control
On this page:
- Overview and Institutional Commitment
- General Information/Guidelines
- International Travel
- Training
- Forms
- Frequently Asked Questions
- Contact Information
Overview and Institutional Commitment
Export Controls are a series of federal regulations that govern the export of sensitive materials, technology, or software in order to protect national security or foreign policy objectives. Wright State University’s policy is to fully comply with all requirements of the US export control laws that apply to activities at Wright State.
Policy
Policy on Export Controls and Trade Compliance (University Policy 6150).
General Information/Guidelines
- U.S. Export/Trade Controls Compliance
- U.S. Export Controls: Background
- Decision Tree
- U.S. Export Controls: Resources
International Travel and Export Compliance
International Travel is a necessary component of a busy and engaged higher education institution. There are many precautions that can and should be made prior to one’s trip. Export Control laws may impact your ability to travel to or through certain countries, the technology you take with you, or the information you present abroad. Please contact our office at least two months in advance of international travel when there is a potential for a regulated export.
Pre-Approval of Travel and Chrome River: When travel is international and includes research activities (e.g. (a) the collection, presentation, or sharing of data or results; (b) research collaboration; or (c) the physical transport of regulated materials), institutional pre-approval is required and Export Compliance issues must be addressed. To determine if there is an export or other issue to avoid or manage, researchers are required to submit basic information about their activities using the Export Compliance-Travel Screening/Certification Form. Factors considered during the review include: the destination and way points, the field of study of the traveler, and the specific purpose of the travel. In some cases, even though the research field does not typically include the technologies subject to Export Control regulations, devices (computer, iPhone, etc) that use an encryption technology may be subject to seizure or contents being copied at the border. Penalties for unapproved exports of controlled materials or information can be significant for the traveler.
Procedure: if you are traveling internationally and some aspect of research will be involved, please download and complete the form linked below and upload it during the Chrome River Expense/Pre-Approval process. The responses need not be lengthy. If a more detailed description or management plan is required, you will be contacted.
Export Compliance Travel Screening Form
Technology and Travel: Faculty and staff of Wright State can checkout a laptop/travel kit through CaTS when working or conducting research while traveling. The travel kit consists of a laptop, domestic and international charger, and cell phone for connecting to Wright State’s virtual desktop server.
For more information, or to request a laptop travel kit, contact the CaTS Help Desk at 937-775-4827. You will be asked to sign an agreement acknowledging your responsibilities and provide a FOAP for any accrued charges or damages to the equipment. Requests should be made at least three business days in advance; limited quantities are available. You are responsible for knowing the restrictions and following the laws of the country you are traveling to in regards to encryption technologies and internet use.
- Dept. of State Travel Alerts and Warnings
- Dept. of State travel information
- FBI guide for Business Professionals Traveling Abroad
- FBI guide for US Students Traveling Abroad
Training
- CITI Module covering Export Control regulations
- See instructions (PDF) for accessing the Export Control module
- Guide for required and recommended courses (PDF)
- Dept. of Commerce online training
Forms
- Export/Trade Compliance Review
- Technology Control Plan Template
- Annual Certification
- Restricted Party Screening Procedure
- Traveling with Electronic Devices Guidance
Frequently Asked Questions
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Who needs to be aware of export control (EC) restrictions?
All faculty, staff and students would benefit from an awareness of export control restrictions. Sign up for an in-person training session or take the export control courses available through CITI
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What types of transactions or activities fall under EC restrictions?
Many different types of activities can be impacted by export control laws, especially:
- Dept. of Defense funded research
- International travel
- International shipping and receiving
- Distance learning
- Foreign visitors/Visa
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How do I know if I should be concerned?
Review our Export Control webpage and resources or contact us at exportcompliance@wright.edu
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If I am travelling within the United States do I need to do anything specific?
No. Travel within the United States does not create an export control concern.
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If I am travelling internationally, what should I do?
Register your travel in the Chrome River system as soon as possible. Contact CaTS to utilize their clean laptop and cell phone program.
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Are there international destinations that are more problematic?
Yes, travel to Iran, Cuba, North Korea, Syria, and the Crimea region are comprehensively sanctioned countries and require special government authorization before traveling. It can take more than six months to get permission, so contact the export compliance officer as early as possible.
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I want to collaborate with international faculty members on a project. How should I proceed?
Collaborations with comprehensively sanctioned countries (Iran, Cuba, North Korea, Syria, and the Crimea region) and/or military technologies are problematic but the majority of international collaborations will not have EC issues. To be safe, please contact our office to briefly discuss your ideas.
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Are there any exceptions to EC rules for universities?
- Fundamental research – This exclusion is based on National Security Decision Directive 189, which defines “Fundamental Research” as: “Basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community, as distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons”
- Public Domain - The ITAR and EAR each have specific definitions of what constitutes “public domain.” However, the general intent is that information is not subject to control once it has been published (lawfully) or made generally available to the public through means such as public libraries, published patents, release at open conferences, and publishing on an open website.
Contact Information
Neal Sullivan, Ph.D.
neal.sullivan@wright.edu, 937-775-3418
