Export Control Review Request

Export Control Review Request

Export Control laws are U.S. laws and regulations that govern the export of strategically important technology, services and information to foreign entities. This checklist provides a diagnostic tool to determine the need for additional review and further action for UMMS initiated foreign activities (non-sponsored research).

If any of the answers in are "Yes" - consultation with the appropriate UMMS Responsible Policy Administrator is required and a license from the Department of State or Department of Commerce may be necessary. Responsibility for export compliance rests with the exporter. Administrative and criminal penalties exist for violations of U.S. export law.

 


Review Checklist

Note: all questions are required.

Does your project:
1. Involve travel or transporting materials, equipment, software or technology to a foreign country during the course of the project?
2. Restrict project participation (faculty, student, others) based on country of origin or citizenship?
3. Involve specific access and dissemination restriction (e.g., restriction of participation by foreign nationals, or restrictions of publication including reporting of research results) or restriction of presenting at conferences?
4. Involve equipment, software, chemicals, bio-agents, or technology designed or modified for military use?
5. Involve research containing source code for encrypted software (other than publicly available software)?
6. Involve a sponsor?

If you answered NO for question #6 please continue to question #11 otherwise please answer the following questions
7. Involve a foreign sponsor ?
8. Involve a sponsor that is a defense agency or contractor?
11. Involve the PI or any research personnel providing data, services, conducting transactions or traveling to embargoed/sanctioned countries?
12. Have you registered your project with the Office of Global Health? ( http://www.umassmed.edu/globalhealth/foreignprojectpolicy.aspx )
See list of sanctioned countries at http://www.ustreas.gov/offices/enforcement/ofac/programs/
See also the Department of State Country Policies and Embargoes List: http://www.pmddtc.state.gov/embargoed_countries/index.html


Certification

I certify that I understand and will comply with all applicable export control laws and regulations as described at: http://www.bis.doc.gov/licensing/exportingbasics.htm