Export Control

silhouetted person looking at a map
 

Export Control

Export Control at RIT

Export control regulations are a complex set of laws that govern the transfer of information, technology, software, and other items and services. These regulations exist to address concerns related to national security, economic competitiveness, and support of international treaties and foreign policy.

At RIT, we are fully committed to complying with all U.S. laws and regulations. Our commitment includes adhering to rules controlling the export of technologies, services, and products, for both research and non-research activities. The university must also follow federal regulations when faculty and students travel 
to specific sanctioned or embargoed countries for purposes of teaching or performing research.These measures ensure lawful and secure international trade.

OCE oversees the university's export control program, offers guidance to the university community on export control matters, manages export control training, and obtains licenses on behalf of the university when necessary.

Sponsored Research Services (SRS) collaborates with OCE to ensure export control compliance in research activities at RIT. SRS reviews all externally sponsored projects to identify any export control requirements. If you need help determining whether an externally sponsored research project is subject to export controls or if a Technology Control Plan is needed, reach out to the Director of Research Compliance.

For more information about the university's Export Control Compliance Program, contact OCE at complianceandethics@rit.edu.

Comprehensive Sanctions

RIT welcomes collaboration with individuals and countries, as long as it aligns with U.S. federal sanctions and embargoes. However, the U.S. government has "comprehensive sanctions" against certain countries. These sanctions generally prohibit U.S. persons from engaging in most transactions, collaborations, or activities with those countries. There are few exceptions to this rule. As a result, most interactions involving comprehensively sanctioned countries or individuals and entities within those countries are restricted. These measures are in place to ensure compliance with international regulations and maintain security.

Click on each country below for more details on the sanctions that apply.

Cuba with grey background

Cuba

Iran with grey background

Iran

North Korea with grey background

North Korea

Syria with grey background

Syria

Russia with grey background

Russia

Belarus with grey background

Belarus

Crimea, Donetsk, and Luhansk Regions of Ukraine with grey background

Crimea, Donetsk, and Luhansk Regions of Ukraine

It is important to note that the U.S. federal government can change the list of countries under comprehensive sanctions based on government actions. Additionally, actions by the U.S. government can lead to restrictions on other countries, and entities and individuals from said countries, even if the countries are not comprehensively sanctioned.

If you intend to interact with a comprehensively sanctioned country or individual or entity within a sanctioned country, review the OFAC Sanctions List and reach out to OCE at complianceandethics@rit.edu with questions.

Additional Export Guidance

RIT encourages global participation in research and university-related activities across campus. To maintain its role as a hub for research, scholarship, and creativity, it is crucial for RIT to follow U.S. export controls for research and work conducted on campus. U.S. export controls apply to what is known as a “deemed export.” When you share export-controlled technology with an international person located in the U.S., it is considered and export to their home country or countries of citizenship and is a deemed export. For more information, please see to the U.S. Bureau of Industry and Security (BIS) resource on deemed exports.

International collaborations are crucial for RIT. Sponsored Research Services (SRS) provides guidance and reviews the scope of collaboration for a project. SRS also checks institutions against sanctions lists. Here are some key points to consider when collaborating internationally on a research project:

  1. Location: Will the research happen in a sanctioned, embargoed, or other high-risk country?
  2. Parties Involved: Who is involved? Are they restricted parties?
  3. Nature of Collaboration: Does collaboration relate to weapons, warfare, munitions, nuclear materials, or national intelligence?
  4. Related Parties: Are any related parties foreign government, military, or intelligence agencies?
  5. Agreements: Has any related party requested a material transfer agreement, nondisclosure agreement, or confidential disclosure agreement in relation to the collaboration?
  6. Shipping and Travel: Will items be shipped, hand-carried, or transferred outside of the U.S.? Is international travel required for involved parties?
  7. Dissemination: Will the results of the collaboration be subject to any restrictions on dissemination?
  8. Incoming Items: Will RIT receive physical items, materials, biologics, software, or proprietary information from international collaborators?


If the answer is “yes” to any of the above questions regarding a research collaboration, please reach out to the Director of Research Compliance for assistance.

RIT works to maintain an open, welcoming environment where visitors and scholars from all over the world can learn, collaborate, and perform research. Federal regulations require the university monitor assignments to foreign persons. Monitoring tasks assigned to foreign individuals ensures that disclosure of and access to export-controlled items and related information is limited to those approved by an export authorization.

Before inviting an international visitor or employee to campus, consider these questions:

  • Is the visitor from a sanctioned country?
  • Is the visitor an employee or agent of a restricted entity?
  • Will the visitor be involved in restricted research or use highly controlled equipment, materials, biologics, or software?

If the answer is “yes” to any of the above questions, please email complianceandethics@rit.edu for assistance.

When conducting international business or research on behalf of RIT, anything shipped, transferred, or transported to a foreign destination is an export. This includes materials, equipment, technology, information, data, and software. When exporting anything 
to a foreign destination, it is important to ensure that all recipients, destinations, and items obtain the necessary U.S. government authorization.

Prior to exporting anything out of the country (including bringing it with you when you travel internationally), consider the following questions:
1. Is the international destination a sanctioned country?
2. Is the person or entity I am collaborating with a restricted party?
3. Will I be taking technology, software, or controlled materials on my trip?

If you answer “yes” to any of the above questions, please email complianceandethics@rit.edu for assistance.

International travel policies and procedures are located on the Controller's website.

RIT's Office of Sponsored Research Services is the central office responsible for supporting and advancing the university’s research mission by providing leadership and expertise in research administration. SRS works closely with OCE to identify and address export control issues related to research performed at RIT.

If you have questions about sponsored research, please contact the Director of Research Compliance.

Training and Education

Classroom with students learning

For general Export Control Training, visit our OCE Training and Education page.

In addition, Sponsored Research Services partners with Collaborative Institutional Training Initiative to offer online training in a variety of research-related topics, including export control, human subjects research, and other relevant topics.

Resources and Information

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 Regulations (OFAC)
OFAC Sanctions List