Guidance/Procedures for the Campus Community
Export and Related Campus Policies
Presentations and Online Courses
Training, Brochures and Awareness Videos
Exports and the University Environment
Letters, Opinions, Comments

Introduction to Export Controls

What are Export Controls?

Export controls are a body of federal regulations that regulate:

Disclosure, shipment, use, transfer, or transmission of any item, commodity, material, technical information, technology, software, or encrypted software for the benefit of a foreign person or foreign entity anywhere (including the transfer of controlled information within the U.S. “deemed export”).

Transactions and the provision of services involving prohibited countries, persons or entities based on trade sanctions, embargoes and travel restrictions.

Certain transactions with persons or entities designated on a federal restricted parties lists.

Common Definitions and Terms

Common Acronyms

Do I Needs to Comply?

All members of the Campus Community must comply with U.S. export control laws when conducting any Activity (1) on University controlled premises, or (2) on behalf of the University at any domestic location, or (3) on behalf of the University at any foreign location.

Please refer to P212 for definitions of Campus Community, Activity and University.

How Do I Comply?

The Office of the Vice President for Research provides a variety of campus training resources and guidance documents (step by step procedures) to support the Campus Community with their compliance with export control laws.

What Can Happen if I Don't Comply?

Penalties, fines, and sanctions (and in some cases jail time) can be imposed on the individual and/or the university for violation of the regulations. Voluntary disclosures can be made by the University to the federal agencies and may result in reduced penalties and/or sanctions if it is found that a violation had occurred.

How Can I Contact SBU's Export Control Officer?

  • Email: susan.gasparo@stonybrook.edu or osp_exportcontrol@stonybrook.edu
  • Phone: 631-632-1954
  • Online Form which can include attachments (NetID and password is required)

How to Comply

Guidance and Procedure Documents for Compliance

While most university and research activities do not require an export license, there are times even when you are conducting research or teaching that an export license, documentation of a license exception and/or a technology control plan will be required for compliance with the regulations.

People

Restricted Party Screening - Who Should be Screened

How to Conduct a Restricted Party Screening

Foreign Person Employee Guidance

International Collaborations Guidance

International Visitor Guidance

Places

Conferences - Hosting, Attending or Presenting Guidelines

Electronic Communications Guidance

International Shipment and Transfer Guidance

Shipper Self-Assessment Review Procedure

International Travel Guidance

Things

Classification of Item/Information Procedure

Purchase of Goods Guidance

Software and Encryption Guidance

Other than Tools of the Trade Self Assessment Review Procedure taking items outside of the U.S. that do not qualify as Tools of the Trade

Record Keeping Requirements

Federal Record Keeping Requirements

Reference Documents to Guidance/Procedures Above

Appendix 1: Terms as Used in the Guidance/Procedures Documents

Appendix 2: Category Definitions for Restricted Party Screening

Questions - Contact SBU's Export Control Officer

Policies

Research Foundation of SUNY and State University of New York Institutional Commitment to compliance with federal export regulations

Research Foundation for SUNY, Export Control Guidance

SUNY, Export Control Guidance

Stony Brook University Export Control Policy (P212)

Stony Brook University Confidential Export Control Escalation Policy

Training Resources

The Office of the Vice-President for Research has the following training resources available to all faculty, staff and students to assist with compliance with the federal export regulations.

December 7, 2016 Recorded Presentation by Don Fischer, attorney and principal of Fischer and Associates

Export Controls: Training and Awareness (NetID and password required)

In Person Trainings

To request a presentation, please contact the Office of Research Compliance at 2-9036.

Collaborative Institutional Training Institute (CITI), recommended as follows:

Faculty, Staff and Students Conducting Research
Export Compliance for Researchers

Faculty, Staff and Students as Appropriate to Research Area
Export Compliance for Biosafety
Export Compliance and International and Foreign Waters
Export Compliance When Using Technology in Research

Faculty, Staff or Students Involved in International Activities
Export Compliance and United States Sanctions Programs
Export Compliance and Collaborations
Export Compliance and Distance Education
Export Compliance for International Shipping

Faculty, Staff or Students involved in Purchasing Activities
Export Compliance for Purchasing

Non-Research Faculty and Staff in Campus Academic/Research Areas
Introduction to Export Compliance

Staff in Office of the Vice-President for Research
Export Compliance for Research Administrators

Staff in University Business Offices
Export Compliance for Operational Departments

Go to out CITI Training page to learn how to access CITI

Other Resources

Letters to Federal Agencies, Guidance Documents and Articles

Association of American Universities (AAU) Universities and Export Controls

Association of University Export Control Officers

Council on Government Relations (COGR) Universities and Export Controls

Notable University Cases

Sharing and Shipping Export Controlled Information - Ignorance is Not a Defense

On January 18, 2012, John Reece Roth, a former professor of Electrical Engineering at the University of Tennessee (UT) in Knoxville, began serving a four-year prison sentence for his September 2008 convictions. Roth received this sentence for illegally exporting military technology, in large part due to his work with graduate students from Iran and China. Although, Roth claimed he was ignorant of the regulations, the prosecution pointed out that he was warned on a number of occasions, including by university counsel, that the technology may have been controlled. Professor Roth's conviction and prison sentence forcefully remind the research community, as well as academia, of the potentially severe consequences that may arise from ignoring technology export controls.

Sharing Non-Public Information from a NIH Grant

In May 2013, three researchers at the New York University School of Medicine were charged for sharing with Chinese companies non-public information about their N.Y.U work conducted through a grant from the N.I.H. to develop new M.R.I. technologies.

Shipping an EAR99 (low level control) Item to a Restricted Party

In March 2013, University of Massachusetts in Lowell (UML) has been sanctioned for two past violations of the Export Administrations Regulations: in 2006 and 2007 UML exported an antennae and an atmospheric testing device as EAR99 to SUPARCO, an organization listed on the Entity List (one of the Restricted Parties Lists).

Sharing Sensitive Federal Government Information via the Internet

In 2009, Georgia Institute of Technology allowed Internet Users in 36 countries, including China, and Iran, to view sensitive information that was intended only for federal employees and contractors. This course included 14 PowerPoint slides and was uploaded to Georgia Tech's servers. The State Department stated that it had determined that violations had occurred.

Shipping an Export Controlled Item Without a License

In 2004, Dr. Thomas Campbell Butler, M.D., a professor of Texas Tech University received a 2 year prison sentence for illegally exported the Yersinia pestis (human plague), which is a controlled item under the EAR and cannot be exported without the required export licenses. Dr. T. C. Butler had to resign from Texas Tech and accepted a denial of his export privileges for a period of ten years.

Other Violation Cases (non-University)

Bureau of Industry and Security, Department of Commerce "Don't Let This Happen to You" Brochure

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