Export Controls and Trade Sanctions

Export controls is a broad term applied to U.S. laws, including trade sanctions,  that regulate the distribution of strategically important technology, services, and information for reasons of national security, foreign policy, and economic objectives. Export controls are the law, and they apply to all activities, not just federally-funded research. Non-compliance can result in civil and criminal penalties for both the individuals and the institution.

Fundamental research (basic and applied research in science and engineering, the results of which are published and shared broadly within the scientific community), educational information (general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities), and public domain information (information which is published and which is generally accessible or available to the public) are not subject to export controls regulations. Proprietary research and industrial development may be subject to export controls regulations. If you are engaging in a research project, it is important not to accept terms in an agreement that restrict publication of the data or who can work on the project, as this invalidates the fundamental research exemption from export controls regulations.

Projects that involve engagement with sanctioned countries or entities also may be subject to restrictions. Before planning projects that involve sanctioned countries or entities, contact one of the people listed below. The following countries--Iran, Cuba, North Korea, Syria, Sudan (as opposed to South Sudan)--are of special concern. If you are planning to engage with these countries in any way, including travel to, activities in, or activities involving nationals of these countries, contact one of the people listed below.   

Sanctioned entities are not limited only to the above countries.    Screening of prospective transactions involving international parties can be conducted using the Consolidated Screening List.  This is a comprehensive list of all entities sanctioned by the US government and, in particular, the US Treasury Department’s Office of Foreign Assets Control (OFAC).

Exporting material goods abroad is always subject to export controls, but not all items will require a license to export. Contact one of the people listed below if you plan to ship or hand carry items abroad.  

Is your project subject to federal Export Control regulations?

  • Will your project involve international travel for yourself or project participants?
  • Will your project be conducted abroad?
  • Will your project involve international shipment or hand-carrying of any physcial items, such as equipment or software (including any Middlebury-issued laptop PCs, cell phones, and/or other mobile data devices)?
  • Whether the activity will be based in the US or abroad, will your project involve involve foreign nationals (i.e. anyone who is not a U.S. citizen, a permanent resident, or a protected individual such as a refugee)?
  • Will your project involve bringing foreign nationals to the United States?
  • Does your project involve funding from the U.S. Department of Defense or from other agencies/sources for defense-related, military-related, or intelligence-related purposes?
  • Does your project involve restrictions, such as publication restrictions or participation restrictions?
  • Does your project involve funding from a company or from a foreign source?
  • Does your project involve the use of proprietary information?

If the answer to any of these questions is YES, then your project might be subject to federal Export Control regulations.    

Planning a project? Contact one of the people listed below for further information.   

Submitting a proposal for a grant or contract? Check YES on the Grant Proposal Endorsement Form (formerly known as the "blue sheet"); someone will contact you.

Questions? Need more information?

Middlebury Institute for International Studies at Monterey (MIIS): Steve Marino

Middlebury College, Language Schools, Schools Abroad: Franci Farnsworth

International Student and Scholar Services, including H-1B temporary work visa applications (Form I-129) Certification for international employees: Kathy Foley

Center for Nonproliferation Studies (CNS) at MIIS:  Robert Shaw


Training   Anyone affiliated with Middlebury may do the CITI Export Controls module and earn a certificate. The first time, you will need to REGISTER (select Middlebury) and then select Export Controls.  


U.S. Department of the Treasury: Sanctions Program and Country Information web page has in-depth information about current sanctions programs

Stanford University: useful Export Controls web page that lists export-controlled or embargoed countries, entities, and persons

Duke University: Embargoed/Sanctioned Countries web page groups countries by category of embargo or sanction (please note that the Restricted Regions page reflects Duke’s own rules, not federal policy)

National Council of University Research Administrators (NCURA): Video - Four Key Concepts of Export Controls is an excellent and concise (3 min.) video on the export controls most relevant for academic institutions.