Export Controls

Overview

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The Office of Export Controls at the 51在线 helps faculty, researchers, and staff navigate the complex environment of export regulations. USF is committed to the highest level of compliance with U.S. export control regulations.

The 51在线's Export Controls materials found on this website are specifically tailored to the USF research community. USF's export control content may not apply to your specific situation or may be incomplete. The University of South 51在线's export control materials do not constitute legal advice. Those outside the USF research community should not act or rely on any information on USF's export control website and should seek the advice of an attorney before taking any action.

View USF Export Control Manual

What USF Researchers Need to Know

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Educate yourself about export controls. You don't have to become an expert, but you need to have a fundamental understanding of the subject to be able to know when to raise questions and alert the university to a possible export controls issue. The materials on this web site have been developed for that purpose, and the Office of Export Controls would be happy to conduct educational sessions on export controls to provide information in a classroom setting or online.

Fortunately, most of the research at USF qualifies for the Fundamental Research Exclusion (FRE). The results of projects that are conducted under the FRE, with the intent to publish the results and in the absence of any other contractual restrictions, are generally excluded from export controls.

When do I contact the Office of Export Controls?

If any of the following applies to you or your research, please contact the Office of Export Controls:

  • I plan to travel outside the United States.

  • I plan to have foreign national(s) participate in my research.

  • My research involves subjects related to nuclear, chemical, and/or biological, weaponry, missiles, unmanned vehicles, or encryption technologies.

  • My project has contractual restrictions on publishing, proprietary information, or foreign national participation.

  • My RFP is marked "Export Controlled."
    I want or plan to collaborate with a researcher or institution from outside the United States (PDF).

  • I will receive nuclear, military or space related information, technical data, equipment or software.

  • I need to ship items internationally.

How can export controls affect my research?

There are several scenarios that may require an export license including, but not limited to:

  • A physical transfer/disclosure of an item outside the U.S.

  • Any transfer/disclosure of a controlled item or information within the U.S. to a foreign national

  • Participation of foreign national faculty, staff, or students in affected research

  • Presentation/discussion of previously unpublished research at conferences or 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 national scholars
     

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Principal Investigator Responsibilities

The PI has primary compliance responsibility regarding export control laws and regulations. The USF Chief Export Control Officer will assist the PI in fulfilling those responsibilities.

Prior to beginning any research project that may be subject to export control laws and regulations, the Principal Investigator should notify, as early as possible, the Export Control Officer that the work planned may be subject to export controls under EAR, ITAR or OFAC. The Export Control Officer will review the proposal or statement of work and contract to determine if the technology involved is subject to export controls.

If the planned research is subject to export controls and is funded, before starting work on the research project, the investigator(s) will cooperate with the Office of Export Controls to manage the specific export control issues. Management mechanisms include, but are not limited to the following:

  • A customized Technology Control Plan (TCP) that will outline the provisions for protecting the controlled technology and technical data such as physical/information security plans and end-of-project security measures.
  • Export Control Training for all the personnel involved in the project.
  • Personnel screening against Denied Persons Lists.
  • Obtaining an export license from the appropriate federal agency, if required. Note: Licensing takes an average of six months.

During the project, it is the responsibility of the PI to inform the USF Chief Export Control Officer of any changes to the scope of the project and additions to project personnel for reevaluation of the export control mechanisms in place. The TCP will also need to be updated accordingly.

The PI and the project personnel will ensure that the access of foreign nationals to the restricted data or technology is denied unless an export license has been obtained.

It is the PIs responsibility to report to the Export Control Officer any violations of export control laws and regulations related to his/her export controlled project.

At the completion of the project and/or when leaving/terminating university employment, the PI will ensure that the restricted technology is securely removed/stored and the restricted technical data is disposed of according to the end-of-project security measures outlined in the TCP.