Export Controls and Trade Sanctions
All programs abroad are subject to export controls and trade sanctions. Exporting, publishing, or sharing certain types of scientific or technical data may pose a threat to national security. Therefore, the U.S. government has the authority to limit access to, or dissemination of, certain types of information produced through academic research by classifying it or controlling it for export. If the government classifies a project or controls it for export, the College must comply with restrictions governing the way that the information produced is handled—including any export licensing requirements that may apply before sending the information, or technology resulting from it, out of the country. In some cases, foreign nationals may also be barred from participating in such projects and/or receiving the information produced, even if it does not leave U.S. territory.
Fundamental research—basic and applied research in science and engineering, the results of which are published and shared broadly within the scientific community—generally is not subject to export controls and trade sanctions. Proprietary research and industrial development are more likely to be. Projects that involve engagement with sanctioned countries or entities also may be subject to restrictions. Before planning projects that involve the following countries (travel to, activities in, or activities involving nationals of those countries) contact one of the people listed below: IRAN, CUBA, NORTH KOREA, SYRIA, SUDAN (as opposed to South Sudan).
These requirements apply to all activities whether or not there is grant funding involved. Non-compliance can result in criminal prosecution of individuals who export the data or technology in contravention to regulatory requirements, and substantial penalties and fines for the institution.
Is your project subject to federal Export Control regulations?
- Will your project involve international travel for yourself or project participants?
- Will your project involve international shipment or hand-carrying of any equipment or software (including any Middlebury-issued laptop PCs, cell phones, and/or other mobile data devices)?
- Will your project involve sponsorship or coordination of any workshops, conferences, seminars, training programs, research collaborations, or similar activities that will in turn involve international participation (whether the activity will be based in the US or abroad)?
- Does your project involve funding from the U.S. Department of Defense or from other agencies/sources for defense-related purposes?
If the answer to any of these questions is YES, then your project might be subject to federal Export Control regulations.
Submitting a proposal for a grant or contract? Check YES on the Grant Proposal Endorsement Form ("blue sheet"); someone will contact you.
For any projects (whether funded with Middlebury resources or external grants or contracts) that will:
- be conducted abroad
- involve bringing foreign nationals to the United States
- involve transferring equipment to other countries
Monterey Institute for International Studies: Steve Marino
Middlebury: Franci Farnsworth
H-1B temporary work visa applications (Form I-129)
Certification for international employees: Ben Bruno
Center for Nonproliferation Studies (CNS) at the Monterey Institute
for International Studies: Robert Shaw
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.