U.S. law limits the export of certain technologies, including both actual equipment and knowledge about the equipment and processes. The list of technologies extends beyond the obvious military items and can include seemingly innocuous items such as laptop computers. The list of restricted destinations also extends beyond the obvious countries, and includes transfer of knowledge to individuals from certain countries, that may actually be in the U.S. on legitimate visas.
The civil and criminal penalties to organizations and individuals are severe. The University of Oklahoma takes its responsibilities seriously, and coordinates all export control activities through its Export Control Officer, who is ready to help you determine if your activities come under the export control regulations, and obtain the necessary approvals if necessary.
Export Control Background
It is critical that everyone at the University of Oklahoma understand the possible impact of laws regulating the release of equipment, technology technical data, technical services, commodities, software, and computer code to foreign destinations and foreign persons. All University employees must be aware that providing, purposely or inadvertently, these items to foreign destinations or foreign persons may result in violation of federal regulations. Civil and criminal penalties exist for these violations and they may be imposed against the University as well as the individual employees involved.
Although much of the work the University of Oklahoma undertakes is excluded from regulation, it is possible that certain technologies and commodities may not be freely shared with all foreign persons, whether they are graduate students, research assistants, post-doctorate scholars, visitors, colleagues at meetings and symposia, contractors or partners in research projects. Likewise, any information concerning these technologies and commodities transmitted from the United States to a foreign destination or foreign person may be regulated regardless of whether it was transferred by mail, telephone, email, facsimile, shipment, via hand-carried materials, over the internet or by any other means.
Export Control Policy
The University of Oklahoma is committed to fully complying with all U.S. laws and regulations. Each employee is expected to support this commitment and is responsible for being aware of his or her obligations and addressing them in a prompt and pro-active manner.
Under no circumstances should the export of controlled commodities or information take place contrary to U.S. export control regulations. Sponsorship of University operations/functions by any agency of the U.S. federal government does not mitigate, supersede, or remove the University's responsibility to adhere to U.S. export control laws.
While export control regulations affect many activities at the University of Oklahoma, the following is a non-exhaustive list of situations that could trigger export control regulations:
Shipping tangible items internationally
Sharing proprietary, confidential or otherwise restricted information or software code with foreign nationals at the University of Oklahoma
Sharing proprietary, confidential or otherwise restricted information or software code with a destination outside the U.S.
Interactions with countries or organizations/individuals from a country currently subject to sanctions or an embargo
Hand carrying laptops, cell phones containing certain microprocessors, and other equipment while traveling to a foreign destination
Exporting or importing an item that has been designed, developed, configured, adapted or modified for a military application
In these situations, the University has a responsibility to either:
Obtain an export license and document this process properly; or
Determine that no export license is required and document this determination properly; or
Determine that while an export license is required, an exception to that requirement exists and document this determination properly