A Primer on Export Controls

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This publication provides a thorough introduction to the complex topic of export control laws and regulations. It's written in a straightforward manner. Topics include key definitions and concepts, which federal agencies oversee regulations, violations and penalties, fundamental research, licensing (and exceptions), international travel, and additional resources.

(30 pages, PDF)

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Table of Contents

Introduction

Key Definitions and Concepts

Who Oversees Export Control Laws?

Department of State Regulations (ITAR)

Regulatory Authority and Scope

The USML Categories

Exporting under the ITAR

Department of Defense (DoD) Funding and Developmental Items

Department of Commerce Regulations (EAR)

Regulatory Authority and Scope

The Commerce Control List

Exporting Under the EAR

The 500 and 600 Series

License Exceptions

Anti-Boycott Restrictions

Department of Treasury Regulations (OFAC)

Regulatory Authority and Scope

OFAC Licensing for Country-based Programs

How Do I Determine What My Item Is?

Commodity Jurisdiction

Commodity Classification

Violations and Penalties

Fundamental Research

ECLs and Universities

How Do I Know if Export Controls Might Apply?

Type of Work Involved

Clauses that Can Nullify FRE

Equipment Involved

Parties Involved (Restricted Party Screening)

International Travel

Summary

Export Control Resources

30 pages, PDF

Jessica B. Buchanan, Ph.D., is the Associate Director of Export Compliance at The University of Pennsylvania (Penn). In this role, she has overall responsibility for Penn's export compliance program. Jessica has presented on export controls and sanctions at NCURA conferences and is an active member of the Association of University Export Controls Officers (AUECO).







Elizabeth D. Peloso, M.S.E., M.B.A., is the Associate Vice Provost and Associate Vice President for Research Services at the University of Pennsylvania. Her office is responsible for pre- and post- award administration of federal and non-profit sponsored research activities and associated agreements, as well as management of Penn's export compliance program. Elizabeth has been an active member of NCURA at the national level, participating as a panelist for NCURA TV, the NCURA webinar series, and as a presenter at national meetings. Missy is an active member of the Association of University Export Controls Officers (AUECO).