Export Controls: The Basics

The Department of State, through its International Traffic in Arms Regulations (ITAR) of the Directorate of Defense Trade Controls (DDTC), and the Department of Commerce, through its Export Administration Regulations (EAR) of the Bureau of Industry and Security (BIS), have implemented regulations governing export of certain technologies, information, and software. The U.S. export controls also apply to “re-exports” of items, software and technology subject to U.S. law from one foreign country to another. In addition, the Department of Treasury, through its Office of Foreign Assets Control (OFAC), maintains targeted economic sanctions programs that restrict or prohibit a wide range of export and other transactions which may include educational services involving designated countries, entities and individuals.

If anyone employed by, acting on behalf of, or associated with the university, including students, receives Information identified as “export controlled,” the information may not be disclosed to any “Foreign Person,” until the export control analysis has been completed to determine licensing requirements, if any, for such information. In addition, if an anticipated GW research or educational activity involves a country subject to U.S. government sanctions, the faculty member or researcher also will need to consult with GW’s Office of the Senior Vice President and General Counsel before entering into any negotiations or agreements involving, or before traveling to, such countries.