Export Controls-Office of Research Integrity and Compliance - Carnegie Mellon University

Export Controls

Why should I be concerned about export controls in conducting research or other activities at CMU?

The university campus is diverse and open to students and faculty from many different countries. Exporting controlled materials, items, or technology to a foreign country (export) or providing access to export controlled technology in the United States to an unauthorized foreign person (deemed export), could result in severe criminal or civil penalties for the university and the university employee involved in the export. Prosecution of an export violation may result in fines of up to $1M and/or a prison sentence of up to 20 years.

How do exports occur at CMU?

Although most research and activities at CMU may be eligible for certain types of exemption under the regulations, nonetheless, export implications may occur in sponsored research awards , NDA’s, contracts, demo of prototypes, international collaborations, work at foreign campuses, industry agreements, foreign national participation, lab tours with controlled technology, encryption software, foreign travel and various other activities.  It is very important that CMU faculty and staff have a good understanding when export red flags may be triggered.

What is an export?

An export is an actual shipment or transmission of items, services, release of technology or technical data subject to either the EAR or the ITAR out of the United States, or release of technology, software, or technical data subject to either EAR or ITAR to a foreign national in the United States (deemed export).  Items, services, technology, software, or technical data can be "released" for export through:

  • visual inspection by foreign national of U.S. origin equipment and facilities,
  • oral exchanges of information in the United States or abroad,
  • transfer or shipment via any means (physical or electronic) to a foreign entity
  • providing a service, or the application to situations abroad of personal knowledge or technical experience acquired in the United States.