Your Compliance Responsibilities
What are my compliance responsibilities?
In general, all University personnel (faculty, students, and staff) are responsible for understanding and complying with U.S. export control laws and regulations and with Brown’s Export Control and Economic Sanctions Policy.
The Export Control Compliance Team within the Office of Research Integrity will help you comply with the laws and policy: we provide a variety of trainings, offer guidance, and facilitate the export license application process. Contact us with any questions!
Are there situation where I am required to contact the Export Compliance Team?
Yes, there are a number of situations where you are required, per Brown’s policy, to contact and work with the Export Compliance Team. These are as follows:
- If you plan to travel to a comprehensively embargoed country;
- If you plan to purchase or receive technology, technical data, or materials that are listed on the USML and are controlled under the ITAR;
- If you are asked by a funder or research collaborator to perform classified or unclassified-restricted research [Note: Brown does not accept classified research on its campus];
- If you receive a collaboration or non-disclosure agreement from a third party research collaborator that contains references to “export controls” or “controlled technology or data”;
- If you receive a request (verbal or written) from a research sponsor or program officer that restricts dissemination of research results, requires publication pre-approval by the sponsor, or limits involvement of foreign nationals;
- If you receive a request (verbal or written) or agreement/contract that supports a restrictive trade practice or boycott imposed by another country, you must report this to the Export Control Compliance Team, who, in turn, are obligated by law to review and, when required, report it to the Department of Commerce.
- If you develop or build new technology for primary military applications.
- If you plan to provide online instruction or courses, including via MOOCs to students in comprehensively embargoed countries.
When should I seek assistance or guidance from the Export Compliance Team?
While we encourage you to contact the Export Control Compliance Team at any time with export control related questions, here are number of situations where you should seek assistance:
- If you travel outside the U.S. with technology or encrypted devices and you are not sure whether that technology or encrypted device requires an export license.
- If you wish to ship research materials and technology abroad and you are not sure whether the materials and technology require an export license.
- If you plan to travel to a country with a limited sanctions program
- If you are hosting visiting scholars, scientists, students, or trainees from comprehensively embargoed countries
- If you are working with groups or organizations that may be on a Restricted Party list (RPS), such as current and former rebel groups, current and former terrorist organizations, members of current or former dictatorships or undemocratic regimes.
- If you are purchasing special research equipment that may be highly restricted. If vendor quotes or sales agreements contain references to “export controls” or “ITAR” or “EAR”, contact the Export Control Compliance Team for assistance.