Export Controls Q&A

Your trip will not be greatly affected by export control issues. On the facts presented, your use of the laptop, as well as the students’ use of their cell phones and iPods, is likely allowable under export control laws.

Yes. Sudan is on the list of OFAC-sanctioned countries, and even visitors with humanitarian intent must comply with heavy restrictions. Under U.S. law, the laptop and GPS device may not be taken to Sudan without a special license, obtained in advance, from the appropriate government agencies. Contact the Office of General Counsel for assistance in submitting a license application. In addition, the sanctions limit the value of goods returned from Sudan to US$100 total - thus, the student would not be allowed to buy the painting.

It is very likely that this research is export controlled, and you could lose certain protections under the law by signing a document that includes any of a number of key terms. As important as this grant may be, you probably don’t want it if it would result in you inadvertently violating the law and subsequently facing fines, prison time, and loss of all future federal funding. Therefore, you should send the document to the Office of General Counsel for review, and possible negotiation of these terms.

Assuming that that the results are (or will be) published and generally accessible to the public (or shared broadly within the academic/scientific community), the dissemination of this information to a Chinese foreign exchange student likely falls under an exception to the export control laws.

*The questions presented in this Q and A are hypotheticals - therefore, the answers should not be relied upon as legal advice. For a specific analysis of the effect of export control laws on your specific situation, contact the Office of General Counsel.

June 2013