If you do any of the following, you may be an exporter:
- Teaching foreign nationals about the use or design of export-controlled equipment, tools, or related technologies
- Sharing third-party controlled proprietary information with a foreign national in the U.S. (even in your own lab) or with anyone outside the U.S. as part of a research project
- Providing a service or anything of value to a sanctioned country (e.g., Cuba, Iran, North Korea, Syria, Sudan)
- Exporting items by mail, FedEx, freight forwarder or by hand-carrying
In general, the export control regulations cover three main types of University activities:
- Shipments from the United States to a foreign country of physical items.
- Travel to a sanctioned country or transactions involving sanctioned individuals or entities
- Verbal, written, electronic or visual disclosure to, or sharing with, foreign nationals of controlled scientific and technical information related to export-controlled items, even when it occurs within the United States
If you are conducting international travel for the University, you must be aware of the export compliance responsibilities you may have in connection with your trip.
International travel screening
OHSU has created a tool to ensure international travelers are secure in knowing that they have the information needed to be compliant with U.S. Government regulations and do not inadvertently transfer materials and information to or visit a country or organization that could require an export license.
Please be sure to complete the International Travel Form in advance of your trip.
Hand-carrying items for research in your luggage when going abroad is an export. Depending on the item you are carrying and your ultimate travel destination, an export license may be required. Additionally, whether or not an export license is required, if the items you are carrying are valued over $2500, additional U.S. government paperwork needs to be filed through the Automated Export System (AES) for Electronic Export Information. The Export Compliance Officer will provide a review of your equipment and determine if an export license is required or if a license exception is available and if AES filing is required. Please contact us in advance of your travels as early as possible to ensure there are no delays to your schedule.
The Department of the Treasury, through its Office of Foreign Asset Control, administers economic and trade sanctions that may restrict or require licensing for activities involving specific countries, individuals and entities. Before considering travel to conduct research or educational activities in a sanctioned country, check with the Export Compliance Officer.
Please reference OFAC's Sanctions Program and Country Summaries for the most current list of U.S. Sanctions.
Things you should know about export controls before traveling
An export occurs when a transfer is made to a foreign person or to a foreign destination. Transfers may occur during conversations with foreign persons, by giving presentations to foreign persons, or by providing access to information to a foreign person.
In the event that you intend to perform research while outside of the U.S., any material generated by that research would not fall within the definition of "Fundamental Research".
If you will be taking your laptop to a foreign country, please be sure that there are no export-controlled technical data. It is best to take a clean laptop and leave your unpublished research data at home. If you are unsure whether your data may be export-controlled, please contact our office.
Tips and best practices
- Travel only with a "clean" device "wiped" upon return to the U.S.
- During private meetings turn device off and remove battery
- Disable Bluetooth, Wi-Fi, print and file sharing. Switch off mic and camera
- Never let device out of sight. After 90 seconds with foreign customs consider it compromised
- Connect online ONLY through secure encrypted channels
- DO NOT TYPE PASSWORD; copy and paste from a USB drive
- Screen the names of your foreign contacts
- Know WHAT is on your device BEFORE you travel. Information and data may carry restrictions
- Encrypted information may still require an export license
To help protect faculty, staff, and students from inadvertent violation of federal export laws, the Office of Export Controls has developed the following process for international shipping.
- Fill out the International Shipping Form
- Wait for notification of approval from the Office of Export Controls
- You will need authorization before you ship any materials internationally, so please allow enough time to process your request
If you have any questions about the form, please contact us
To help ensure that OHSU faculty, staff and students do not experience customs delays, seizure of goods, or inadvertent violation of export laws, the below describes the basic requirements for international shipping and hand carry of items abroad:
U.S. government regulations are in addition to any other regulations regarding select agents, dangerous goods transportation, or other controls related to the specific item being transported abroad.
Legal requirements for all international shipments
Cuba, Iran, North Korea, Syria and Sudan are countries with strict import and export license requirements. If you have a collaborator, or will be sending or receiving items from one of these countries, contact the Export Compliance Officer regarding license requirements.
Restricted party screening
The U.S. government maintains various lists of individuals and entities that U.S. organizations are prohibited from collaborating with or shipping to, and require an export license for shipment to a restricted party. Please contact the Export Compliance Officer for assistance with screenings or export license applications.
Export license review and declarations
U.S. export regulations may require an export license or license exception based on the item (including technical data), shipping destination, value or end user. Automated Export System (AES) filing for shipments valued over $2500 or those that require an export license are required under the Foreign Trade Regulations. The Export Compliance Officer can assist you by reviewing your shipment and advising on possible license exceptions.
Export Classification can be either an Export Control Classification Number (ECCN) under the Export Administration Regulations (EAR), or a US Munitions List (USML) category number under the International Traffic in Arms Regulations (ITAR). Contact the Export Compliance Officer for assistance with classification when needed.
The Office of Foreign Asset Controls (OFAC) of the U.S. Department of the Treasury administers economic and trade sanctions against specific countries, individuals and entities. These trade sanctions programs apply to University activities. The most comprehensive sanctions involve Cuba, Iran, Syria, Sudan and North Korea.
What do I need to do?
Contact the Export Compliance Officer for guidance as soon as possible, for any of the following, involving a comprehensively sanctioned country, listed individual, or entity:
- Any imports/exports (examples include research samples and equipment)
- Collaboration with individuals residing in a sanctioned country
- Research in
- Travel to (including attending a conference)
- Transfer of funds to
OFAC sanctions change regularly. Please contact the Export Compliance Officer as soon as possible for the most recent guidance to avoid penalties and delays to your research.
If a license is required it will likely take 3 months or more to obtain it.
Who this applies to
OFAC regulations apply to United States persons. The term U.S. person means any United States citizen, legal permanent resident, or green card holder, regardless of whether they are located in the U.S. or abroad. It also includes any entity organized under the law of the United States, or any foreign nationals who are currently located in the United States or in some cases outside the United States.