Export Controls: Triggers

An export may occur through the provision of technical assistance to a foreign person in the U.S. or abroad as well as by other means. For example, sending an e-mail to a foreign student in the U.S. or a U.S. person abroad, making a telephone call to a colleague abroad or by allowing foreign persons to visit a lab or access a computer system at the university could be considered as activities defined under the export control regulations. Before engaging in activities that involve an export, members of the GW community must understand and identify any potential export limitations. Export controls will generally be triggered:

  • Where Foreign Persons will participate in the research;
  • Where GW will partner with a foreign company;
  • Where GW hosts foreign visiting scholars for the purpose of research that involves certain specified technologies subject to export controls;
  • Where equipment needed for educational projects, experiments or research abroad will be exported (i.e., shipped or accompanying the researcher/faculty member or project leaders, including, for example, laptops, GPS equipment, other hand-held mobile devices, etc., or any device that contains encrypted software;
  • Where GW intends to engage in activities with or involving countries subject to U.S. sanctions;
  • Where GW faculty or researchers do not intend to publish or freely disseminate their research results;
  • Where GW faculty or researchers will share certain research results or educational information in any manner (including publication or presentation at conferences) with Foreign Persons - whether these activities take place on U.S. soil ("Deemed Exports") or abroad; or
  • Where export regulations (EAR or ITAR) are cited in the award document. If a researcher or educator accepts export-controlled technology from a government agency or from industry, or creates such technology, the researcher or educator is subject to ITAR and/or EAR regulations.