Export Controls and sanctions involve the requirement by the U.S. government to obtain a license (authorization) prior to exporting certain items outside of the United States.
- “Export” – An actual shipment or transfer out of the United States, including the sending or taking (e.g. hand-carrying) of an item out of the United States, in any manner – e.g. access of software or information by anyone in any location outside of the United States.
- “Items” – University owned or sponsored research materials, equipment, technology, information, data, and software – e.g. University laptops and any sponsored research materials or information.
- Prior to exporting any items out of the country, please consider the following questions:
- Is the international destination a comprehensively sanctioned country – i.e. Belarus, Cuba, Iran, North Korea, Syria, Russia, Ukraine?
- Is an Electronic Export Information (EEI) filing required?
- Is the item(s) I am taking abroad worth $2,500 or more?
- Are you taking University owned items to China, Russia, or Venezuela?
- Are you bringing or accessing any sponsored research information, data, software, or technology that is restricted from publication or dissemination?
- If the answer to any of these questions is “Yes” contact the Export Compliance Office as soon as possible before you begin your travel plans (see Appendix I).
Antiboycott Rules prohibit U.S. persons from taking certain actions with the intent to comply with, further, or support an unsolicited foreign boycott (see Appendix II).
- “Foreign Boycott” – Refusing or agreeing to refuse to do business with a boycotted country that is not sanctioned by the United States.
Under the Foreign Corrupt Practices Act (FCPA), U.S. businesses and their agents are prohibited from making corrupt payments to foreign officials to obtain or retain business – i.e. a “Bribe.” (see Appendix III)
- “Corrupt Payment (Bribe)” – Payments, offers, or promises made for the purpose of:
- influencing any act or decision of a foreign official in his official capacity,
- inducing a foreign official to do or omit to do any act in violation of the lawful duty of such official,
- securing any improper advantage; or
- inducing a foreign official to use his influence with a foreign government or instrumentality thereof to affect or influence any act or decision of such government or instrumentality.
If you receive a foreign bribe or receive a request to participate in any foreign boycott during your travels, please notify the Export Compliance Office immediately.