Export Compliance (EC)

Export controls can affect some activities and operations within an organization that might not be immediately apparent. While your current activities may not involve export controls, circumstances can change. Having a basic understanding of how export controls can affect university transactions will help identify risks in advance and enable your organization and its constituents to maintain compliance at all times.

Fundamental research is excluded from export controls. However, this exclusion only applies to the results of the research, which must be free from restrictions on publication or dissemination. Equipment, data, or software used in the research may be subject to controls.

In addition, since the direction of research can change during the course of the project, what started out as fundamental may develop into something that becomes controlled. Because these variables can evolve suddenly and unexpectedly, your institution can benefit from EC training by learning how to identify situations that will void the fundamental research exclusion.

These courses are designed to provide training on export controls for various roles and operational departments. It is up to the organization to decide if this training is mandatory or elective. The organization may also outline retraining frequency and use reporting tools to see who has taken the training.

CITI Program’s Export Compliance courses raise general awareness of export control issues that can arise during the course of university business. Your organization’s export control office, research administration, and program sponsor can decide together whether it fulfills the training requirements outlined in the agreement.

There is no uniform standard regarding how frequently EC training should occur. If an organization wants its learners to complete refresher training, it is recommended that the refresher course be taken approximately three years after learners have completed a basic EC course.