Are University Classes Subject to the Export Regulations?

Are University Classes Subject to the Export Regulations?

The export regulations provide exclusions for educational activities that allow for the teaching of commonly taught information to continue at universities.

Export Administration Regulations (EAR)(15 CFR § 734.3(b)(3)):

Information and "software" that "are released by instruction in a catalog course or associated teaching laboratory of an academic institution" are not subject to the regulations.

  • Where - academic institution
  • How - while conducting the instruction of a course or the course's associated lab class
  • What - appears in a course catalogs
  • Does not cover encrypted software
  • This exclusion may be void if that same information is transferred to a foreign person outside of class.

International Traffic in Arms Regulations (ITAR)(22 CFR §120.10)

"Information concerning general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities".

  • Where - academic institution
  • How - implied - while conducting the instruction of a course or the course's associated lab class
  • What - focuses on subject matter (implied - appears in course catalog)

What About Massive Open Online Classes (MOOC)?

MOOCs are actively delivered,interactive and graded. MOOCs are viewed as a service and therefore users in Cuba, Iran and Sudan have limited access and users in Crimea are blocked under the Office of Foreign Asset Controls (OFAC) sanctions programs.

SUNY has a partnership with Coursera to deliver MOOCs.

Go to top