Export Controls

Export controls have become an essential part of research compliance, especially since Universities are replete with scholarly work that may depend on international collaborations.  Export Control Laws exist to regulate the export of things, tangible and intangible, out of, into, and within the U.S.  The U.S. Department of State’s International Traffic in Arms Regulations (ITAR), the U.S. Department of Commerce’s Export Administration Regulations (EAR), and the U.S. Department of Treasury’s Office of Foreign Asset Controls (OFAC) govern the main three export control laws for Universities.  

Export regulations apply to a myriad of transferred items, software, or information to foreign nationals or foreign entities. Prior to the transmission of export-controlled items or information, institutions may be required to obtain a special export license from the Commerce, State, or Treasury Department. The consequences of not complying with export control regulations can be severe and include loss of research funding, fines, and/or prison time.

For detailed information about export controls, please refer to the California State University Export Controls Manual.  Additionally, please refer to the CSU Office of General Counsel Export Control Flowchart to help determine if you qualify for an export license exception or if an export license will be required.  

For helpful descriptions, please refer to Export Controls Frequently Asked Questions.

EMBARGOED OR OTHERWISE RESTRICTED DESTINATIONS, ORGANIZATIONS OR INDIVIDUALS

  • Countries with restricted entities on the EAR Entity Chart
    (15 CFR 744, Supp. 4 - pdf file) China, India, Israel, Pakistan, Russia
  • Office of Foreign Assets Control (OFAC) Embargoed Countries Cuba, Iran, Syria, North Korea, Myanmar (formerly Burma) and Sudan

See Sanctions Program and Country Summaries for more specific information.

  • OFAC Listed Countries and Territories Subject to Sanctions Liberia, Iraq, Zimbabwe, Balkans, Libya, Cote D'Ivoire (formerly Ivory Coast) and the Palestinian Territories

See Sanctions Program and Country Summaries for more specific information.

  • OFAC Specially Designated Nationals and Blocked Persons List
  • ITAR Prohibited Countries: Afghanistan, Belarus, Cuba, Iran, Iraq, Libya, N. Korea, Syria, Vietnam, Myanmar (formerly Burma), China, Haiti, Liberia, Rwanda, Somalia, Sudan, or Democratic Republic of the Congo (formerly Zaire), any UN Security Council arms embargoed country (e.g., for certain exports to Rwanda).
  • Denied Persons List A list of individuals who are denied export privileges by the Commerce Department.

We must consider destinations, nationalities, and screen for restricted parties before traveling to, hiring from, entering into agreements with, shipping, mailing or emailing to, discussing restricted technology with someone from, or procuring from these countries or entities. The countries below are subject to U.S. comprehensive sanctions; exports to these countries or deemed exports to non-U.S. persons from these countries in the U.S. may require securing an export control license before the transfer can occur.

Countries with the Highest Level of Export Restrictions:

  • Cuba
  • Iran
  • North Korea
  • Sudan
  • Syria

External Resources:

Export Controls Online Training 

https://www.bis.doc.gov/index.php/compliance-a-training/export-administration-regulations-training/online-training-room

International Traffic in Arms Regulations (ITAR)

https://www.bis.doc.gov/index.php/forms-documents/technology-evaluation/781-export-licensing/file

Office of Foreign Assets Control (OFAC)

https://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Foreign-Assets-Control.aspx

Export Administration Regulations (EAR)

https://www.bis.doc.gov/index.php/regulations