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Export Control Laws and Trade Sanctions

Export control laws (ECLs) are a complex set of federal regulations designed to protect U.S. national security; to prevent the proliferation of weapons of mass destruction; to further U.S. foreign policy including the support of international agreements, human rights and regional stability; and to maintain U.S. economic competitiveness.  ECLs govern how information, technologies, and commodities can be transmitted overseas to anyone, including U.S. citizens, or to foreign nationals in the U.S.


University research is subject to ECLs including the International Traffic in Arms Regulations (ITAR), implemented by the U.S. Department of State, and the Export Administration Regulations (EAR), implemented by the U.S. Department of Commerce. The Office of Foreign Asset Control (OFAC), which is part of the U.S. Department of the Treasury, is responsible for administering and enforcing economic and trade sanctions against certain nations, entities, and individuals.  ECLs may apply to research activities on campus, to the temporary export of controlled University owned equipment including laptop computers containing controlled software or technical data, and to the shipment of research materials to foreign collaborators. Failure to comply with ECLs can result in severe consequences for the University of Pennsylvania as well as the individual researchers, including fines of up to $1 million per violation, up to 20 years imprisonment, and debarment from future exporting activities.


Even though most research conducted on campus will not be subject to export control restrictions, it is important for the university community to be aware of the University of Pennsylvania guidance on Export Controls.   Additionally, the following materials are available to help researchers and administrators become more aware of the issues surrounding Export Controls and to assist them in determining when the regulations are applicable.  If you think you need to apply for a license, please contact Elizabeth Peloso, Director Export Compliance ( epeloso@upenn.edu or 215-746-0234).

Memo from Senior Administrators on Export Control Laws
A letter from the Senior Vice Provost for Research and Senior Vice President and General Counsel.

Memo from Senior Administrators on Transportation and Travel with Research related Equipment, Materials, and Data

Export Controls FAQs
Helpful FAQs.

The Impact of Export Controls on Higher Education Scientific Institutions Conference



Penn Resources

Decision Tree
Does your proposed activity require detailed review for compliance with Export Control Law?


Playbook for Global Engagement


University of Pennsylvania Export Compliance Manual

Export Control Quick Guides


Export Control Contacts

Information on H-1b and O-1 Visa Petitions and the I-129 Deemed Export Certification

Exporting Chemical and Biological Materials

Considerations for the Temporary Export of Research Equipment

End Use Certification

Technology Control Plan Template
Plan for the control of export controlled items and information

Cloud Computing and Export Controls

Travel to Cuba

External Resources

International Traffic in Arms Regulations (ITAR)

Office of Foreign Asset Control (OFAC)

Export Administration Regulations (EAR)

Council on Government Regulations information and analysis on Export Control

American Association of Universities information on Export control

Tips to protect laptops and electronic devices when travelling

Department of Commerce on-line Export Compliance Training

Consolidated Screening List'

Article on Export Controls and Biological Research

Deemed Exports and Fundamental Research for Biological Items


   
 
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