Export Controls and International Collaborations
In general, collaborations between university personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve export controlled or restricted research or involve scholars in sanctioned countries or at sanctioned entities. Before engaging in an international collaboration, the university needs to determine if export licenses are required and to verify that the foreign individual or organization is not a blocked or sanctioned entity (Restricted Party). Note that some universities are Restricted Parties.
If you intend on collaborating internationally, please contact Brown’s Export Control Officer as early in the process as possible.
Please keep in mind the following, when collaborating internationally or conducting research abroad:
- If you are presenting or discussing research with foreign collaborators, only provide information that is either already published, in the public domain, or has no restrictions on publication.
- If you are providing instruction or training, be sure that the information you are sharing is not controlled for export and that providing a service to the foreign group or the country of destination is allowable (contact the Export Control Officer for assistance).
- Note that providing training or instruction to foreign military personnel, may be considered a “defense service” requiring a license from the Department of State. Please contact the Export Control Officer if you will be providing services or training to a foreign military group.
- Be aware that everything you export is considered an import to the destination country. Check that country’s import regulations well in advance of your trip.
U.S. Embargoes and Sanction Programs
The Office of Foreign Assets Control (OFAC) is responsible for enforcing all U.S. embargoes and sanction programs. Depending on each country’s embargo or sanction program, different activities may or may not be prohibited without a specific government authorization or license.
The OFAC sanction programs can be generalized into three categories:
“Comprehensive” – In general, under comprehensive sanctions programs, ALL interactions and activities are prohibited, including exporting to, importing from, financial transactions of any kind, and/or providing services of any kind. While essentially all interactions with comprehensively sanctioned countries are prohibited, there is an exception for informational materials that allows certain transactions to occur.
“Limited” – Under limited sanctions programs only some activities (e.g., importation of items) are prohibited.
“Regime or List-Based” – Regime or List-Based sanctions are targeted against specific individuals identified by the Treasury Department and referred to as Specially Designated Nationals (SDNs) or are targeted against specific groups of people usually associated with a governmental body or regime.
For additional information on a specific sanction program see OFAC Sanction Program Summaries.