About Export Controls

Does your research project involve: Shipping equipment to a foreign country? Collaborating with foreign colleagues in foreign countries? Training foreign nationals in using equipment? Working with a country subject to a U.S. boycott? Is the RFP marked "Export Controlled"? Is the sponsor requiring pre-approval rights over publications or the participation of foreign national students? IF SO: A determination must be made by MU as to possible license requirements. Contact Jennifer May in the Office of Research (882-3841 or mayj@missouri.edu). Compliance Office & Export Controls Dr. Robert Hall Associate Vice Chancellor for Research & Director of Compliance Jennifer May Compliance Officer 205 Jesse Hall University of Missouri Columbia, MO 65211 573 882-3841 phone 573 884-4401 fax email: mayj@missouri.edu

Federal export control regulations prohibit the export to foreign countries of certain goods, technology, and technical data without an export license issued by the government. These regulations were implemented for reasons relating to national security, economic and trade protection, and the advancement of foreign policy goals. The events of 9/11 in particular have resulted in stricter interpretation and enforcement of these regulations by the administering federal agencies.

University of Missouri investigators need to be aware of export control regulations and the possible impact on research. The term "export" as used in these regulations includes not only the actual export or shipping of goods to foreign countries, but also "deemed exports" which includes the transfer/disclosure in any form (verbal, written, electronic, visual) within the U.S. of export-controlled items or information to a "foreign national" (anyone who is not a U.S. citizen or permanent resident). As a result, where export control regulations apply and where no regulatory exemption is available, an export license will be required before export-controlled items or information can be shared abroad or on campus with foreign nationals participating or collaborating in affected research projects. These activities, among others, may be restricted:

1. The ability of foreign scholars and students to participate in export-controlled research at the University of Missouri;
2. The ability of University of Missouri investigators to disclose or discuss previously unpublished research at conferences and meetings where foreign nationals are in attendance;
3. The ability of University of Missouri investigators to engage in collaborations with foreign investigators, including restrictions on teaching foreign collaborators how to use export-controlled items in research (regulated as providing a "service"); or
4. The ability to send research equipment abroad.

While such restrictions appear at odds with research traditions of open access and dissemination of results, the vast majority of university research is not subject to export controls. This is because the research does not involve export-controlled items or data, or because research involving such items or data qualifies for an exclusion / exemption from the regulations. However, where export control regulations apply, the penalties for non-compliance are severe (up to $1,000,000 per violation and imprisonment up to 10 years) and may be imposed against individual investigators as well as their institutions.

For more information about Export Controls, please feel free to download and review the following presentation:

• Presentation on Export Controls (1.5 MB PDF)
• Presentation on Export Controls (368K Powerpoint)
   
• Advanced Presentation on Export Controls (382K PDF)
• Advanced Presentation on Export Controls (1.11MB Powerpoint)