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"Export" is defined not only as a physical transfer/disclosure of an item outside the U.S., but also as a transfer/disclosure in any form of a controlled item or information within the U.S. to anyone who is a foreign national (not a U.S. citizen or permanent resident). This is called the "deemed export" rule. As a result, unless an exclusion or exemption is available, the university may be required to obtain prior governmental approval (in the form of an export license) before allowing the participation of foreign national faculty, staff, or students in affected research. In some cases, a license may not be available at all based on the country involved.

The following are some additional examples of situations in which a license may be required:

• Presentation/discussion of previously unpublished research at conferences and meetings where foreign national scholars may be in attendance
• Research collaborations with foreign nationals and technical exchange programs
• Transfers of research equipment abroad
• Visits to your lab by foreign scholars

Does the activity involve:

• A foreign company or government sponsor where the activity is conducted here or abroad?
• A foreign national (a person who is not a U.S. citizen or Green Card holder)?
• Foreign Nationals (faculty, post-docs, students, visiting scholars, collaborators, etc.) using equipment on the ºÚÁÏÍø³Ô¹Ï±¬ÁÏcampus?
• A U.S. government contract with a restriction on participation by foreign nationals or other restriction?
• A contract with a U.S. company or the U.S. government that has a publication restriction or an associated NDA or proprietary rights agreement?
• Taking equipment abroad?

If you answered YES to any of the questions above, contact the Office of Export Controls at exportcontrol@usf.edu or by phone (813-974-5638).

A license is not required to send most items to most countries. However, you should always consult with the Office of Export Controls prior to exporting equipment, software (including source or object code), technical data (other than fundamental research results), or encryption technology. A license may be required to hire a foreign national to participate in an export controlled project.

Export licenses are requested on behalf of a researcher by the Office of Export Controls to the appropriate regulatory body. It is important to note that obtaining an export license may take several months and there is no guarantee that the U.S. government will approve a license request.

Yes, in most cases, low-end items that are commercially available do not require export licenses. There are some important exceptions including items containing strong encryption technology or software (e.g., laptop computers, or web-enabled cell phones), items that have dual use applications (e.g., high end GPS units), or that are restricted under other regulations or sanctions.

Export Controls are U.S. laws that regulate, for reasons of foreign policy and national security, the distribution of strategically important technology, services and information to foreign nationals and foreign countries.

ºÚÁÏÍø³Ô¹Ï±¬ÁÏinvestigators engage in a broad range of innovative and important research both in the United States and overseas. These activities include the sharing and development of products, goods, hardware, software, or materials, as well as research involving technology that may be subject to U.S. export control laws and regulations. While our primary mission is education, research and service, the responsibility remains to balance the service of this mission with safeguarding national assets through the adherence to export regulations, rules and laws of the U.S. Government.

Following the events of 9/11 there has been a heightened level of awareness and scrutiny of all export activities with an accompanying emphasis on enforcement. Federal agencies are increasingly focused on universities and their compliance with export regulations. Non-compliance with export regulations can lead to substantial and severe criminal and monetary penalties imposed on both individual researchers and institutions.

The following are the current U.S. Governmental agencies with oversight of export control regulations:

• The Department of Commerce's Export Administration Regulations (EAR)
• The Department of State's International Traffic In Arms Regulations (ITAR)
• The Treasury Department's Office of Foreign Assets Control (OFAC)

Any research activity may be subject to export controls if it involves the actual export or "deemed export" of any goods, technology, or related technical data that is either 1) "dual use" (commercial in nature with possible military application) or 2) inherently military in nature.

Work in the following areas (not inclusive) is considered high risk:

• Engineering
• Space sciences
• Computer Science
• Biomedical research with lasers
• Research with encrypted software
• Research with controlled chemicals, biological agents, and toxins

In addition, any of the following raise export control questions for your project:

• The funding opportunity announcement (BAA, RFP or other solicitation) or terms and conditions mention citizenship/foreign national controls, export controls, or publication restrictions.
• Sponsor restrictions on the participation of foreign nationals in the research.
• Sponsor restrictions on the publication or disclosure of the research results.
• The sponsor is a Department of Defense agency, an intelligence agency, Homeland Security, the National Aeronautics and Space Administration, the Department of Energy, or a defense contractor.
• You will be working with ITAR information or technology, proprietary equipment, software or technical data; particularly if supplied by th