About Export Controls
It is the responsibility of the University, the Office of Export Controls (OEC) and the faculty, staff, and students to comply with all U.S. federal, local, and University policies, procedures, laws, regulations, sanctions, and embargoes in regards to “export controls.” While OU supports the expansive knowledge and educational opportunities research has on its campus, it must also adhere to the explicitly stated guidelines of U.S. governmental regulations in order to maintain its honorable practice. The Office of Export Controls aims to clarify what is considered an export during all research and development stages, educational activities, international travel/seminars/studies, and in all export matters regarding the University of Oklahoma. The majority of University activity is exempt from export control regulations because it is considered “fundamental research” or it involves only publicly available information and technologies. However, research results that are restricted from publication or dissemination, proprietary or confidential technology received from an external source, defense items and technology, and physical exports can be subject to export control regulation and should be reviewed by the OEC.
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 the OEC which is ready to help you determine if your activities come under the export control regulations and obtain the required approvals, if necessary.
Export Control Background
All University employees must be aware that providing, purposely or inadvertently, items listed in the USML or EAR (regulate items/materials by the U.S. federal government) 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 employee(s) 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.
Interaction with Government Investigators
On occasion, a government investigator, auditor, or agent might inquire about information from University persons in order to further their investigation. In any instance of a potential interaction (search warrants, subpoenas, or request for records/information), please contact the Office of Legal Counsel at 405-325-4124 (Norman) and 405-271-2033 (HSC) prior to proceeding further.