Export Control

Overview of Export Controls

Export control regulations are a complex set of laws designed to control the transfer of information, technology, software, other items, and services considered to be important to the U.S. due to concerns about national security, economic competitiveness, or support of international treaties and foreign policy. RIT is committed to full compliance with all U.S. laws and regulations, including those controlling the export of technologies, services, and products, for both research and non-research activities. The university must also follow federal regulations when faculty and students travel 
to certain sanctioned or embargoed countries for purposes of teaching or performing research.

OCE oversees the general export control program, provides counsel to the university community regarding export control concerns, manages export control training, and obtains licenses on behalf of the university when required. Sponsored Research Services is a partner in export control compliance, and reviews all externally sponsored projects for export control requirements. For assistance determining if an externally sponsored research project is controlled, or determining whether Technology Control Plan for a sponsored research project is required, contact the Director of Research Compliance.

For information about the university's Export Control Compliance Program, contact OCE at complianceandethics@rit.edu.

Comprehensive Sanctions

RIT maintains an open approach to all individuals and countries able to collaborate within the confines of U.S. federal sanctions and embargoes. The U.S. federal government maintains “comprehensive sanctions” against certain countries that have the effect of prohibiting U.S. persons from taking part in most transactions, collaborations, and activities with these countries. With few exceptions, the U.S. will bar most transactions, collaborations, or activities involving a comprehensively sanctioned country or individuals and entities from those countries. The countries below are those that currently have comprehensive or equivalent sanctions placed against them.

Note that the countries against whom the U.S. has placed comprehensive sanctions can change based on actions taken by the federal government. 
If you plan on having any interaction with a comprehensively sanctioned country, please contact OCE 
and check the OFAC Sanctions List. In addition, certain actions taken by the federal government can result in similar restrictions placed 
on countries, individuals, and entities from other countries, even if the countries are not comprehensively sanctioned. If you have any questions, please contact complianceandethics@rit.edu for help.

Additional Export Guidance

RIT encourages international involvement in its research and university-related activities across campus. Ensuring that the research and work done while on the RIT campus is in accordance with U.S. export controls is essential if the university is to serve as a center for research, scholarship, and creativity. When conducting research, U.S. export controls can apply to what is known as a “deemed export.” The “release” of export-controlled technology to any international person located in the U.S. is a deemed export to the person’s country or countries of citizenship. For more information on deemed exports, please refer to the U.S. Bureau of Industry and Security (BIS) resource on deemed exports.

International collaborations are particularly important to RIT. Sponsored Research Services provides support through guidance and specific reviews of collaboration scope, as well as helps vet institutions against sanctions lists. In addition, important considerations include:

  1. Will the research take place in a sanctioned, embargoed or other high-risk country?
  2. Who are the parties involved? Are they restricted parties?
  3. Does collaboration in any way relate to weapons, warfare, munitions, nuclear materials, and/or national intelligence?
  4. Is any related party a foreign government, military, or intelligence agency?
  5. Is any related party a domestic military or intelligence agency?
  6. Has any related party requested a material transfer agreement, a nondisclosure agreement, and/or confidential disclosure agreement in relation to the proposed collaboration?Will items ship, travel by hand, or otherwise transferred outside the United States?
  7. Does collaboration involve international travel?
  8. Will the results of the collaboration be subject to any restrictions on dissemination?
  9. Will RIT receive any physical items, materials, biologics, software, and/or proprietary information from a collaborating party?

If the answer is “yes” to any of the above questions regarding a research collaboration, please contact
the Director of Research Compliance for assistance.

RIT works to maintain an open, welcoming atmosphere where visitors and scholars from all over the world can come to learn, collaborate, and perform research. Federal regulations require the university to monitor assignments to foreign persons to ensure that the disclosure of, and access to, export-controlled articles and related information is limited to those approved by an export authorization.

Prior to inviting an international visitor or employee to campus, consider the following

  • Is the visitor from a comprehensively sanctioned country?
  • Is the visitor an employee or agent of a restricted entity?
  • Will the visitor take part in any type of restricted research, or interact with any type of highly controlled equipment, materials, biologics, and/or software?

If the answer is “yes” to any of the above questions, please contact OCE for help.

The university encourages international activities, collaboration, and engagement. When conducting international university business or research, anything (e.g., materials, equipment, technology, information, data, software) shipped, transferred, or transported to a foreign destination is an export. When exporting anything 
to a foreign destination, it is important to ensure that all recipients, destinations, and things obtain the necessary U.S. government authorization.

Prior to exporting anything out of the country, please consider the following questions:
1. Is the international destination a comprehensively sanctioned country?
2. Is the person or entity I am collaborating with a restricted party?
3. Will I be taking any technology, software or controlled materials?

If you answer “yes” to any of the above questions, please contact OCE for guidance.

The Office of Sponsored Research Services is the university’s central office responsible for supporting and advancing the university’s research mission by providing leadership and expertise in research administration. SRS works closely with OCE to identify and
address export control issues related to the research performed at RIT.

If you have any questions concerning sponsored research, please contact the Director of Research Compliance.

Training and Education

For general Export Control Training, visit our OCE Training and Education page. In addition, Sponsored Research Services has partnered with Collaborative Institutional Training Initiative to provide online training in a variety of research-related topics, including export control, human subjects research, and other relevant topics.