Export Controls, Import Controls, and Sanctions
Research collaboration – both in the U.S. and internationally – and cross-border international programs and activities may be subject to national security-related export control, import control, and sanctions regulations.
While exemptions to these controls are afforded to academic research intended for publication without prior restriction, as well as most catalog course offerings, specific conditions apply, per federal regulations.
Some types of sponsored research and some international activities involving destinations or entities of concern in particular may be subject to restrictions, prohibitions, and/or licensing requirements.
This page is intended as a resource for the Middlebury community, serving as an introduction to these controls, suggesting resources for further information, and offering guidance on who to contact for support in complying with federal regulations.
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. Noncompliance can result in civil and criminal penalties for both the individuals and the institution.
The following are not subject to export control regulations:
- 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)
- Public domain information (information which is published and which is generally accessible or available to the public)
Note: Proprietary research and industrial development may be subject to export control 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.
Regulatory requirements also prohibit or highly restrict importation of certain categories of items, including (but not limited to):
- Items specifically military in nature (including some obsolete or historical items)
- Products of endangered wildlife
- Certain antiquities and rare cultural artifacts
- Certain chemicals
- Select biological agents and toxins
- Radiological materials
If you are engaging in research or educational activities that may involve the need to import any of the above into U.S. territory, please contact one of the people listed below for further guidance.
Sanctioned Countries, Entities and Individuals
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, Russia, Syria—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 U.S. government and, in particular, the U.S. 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 physical 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 U.S. or abroad, will your project 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.
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 and Tracking Form (PET Form) and someone will contact you.
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.
For more information, contact Global Operations Manager Vikas Budakoti at firstname.lastname@example.org or any of the specialists below:
- Center for Nonproliferation Studies (CNS) at MIIS: contact Robert Shaw at email@example.com.
- Sponsored programs and faculty research grants: contact Nick Brightman (Middlebury College) at firstname.lastname@example.org or Steve Marino (MIIS) at email@example.com.
- Material Transfer Agreements: contact Katie Gillespie at firstname.lastname@example.org.
- International Student and Scholar Services, including H-1B temporary work visa applications (Form I-129) Certification for international employees: contact Kathy Foley at email@example.com.
- Finance issues (such as carrying cash out of the U.S., paying foreign vendors and individuals, payments from sanctioned entities): TBD
Forms, Policies, and Resources
See our extensive list of important forms and information.
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