Washington University in St. Louis | OVCR
Export Controls: Red Flags

Activities which involve the following "red flags" may be subject to export controls:

  • Contractual restrictions that destroy the Fundamental Research Exclusion​​:
    • restrictions on the university’s right to publish or disseminate project results or information
    • limitations on participation or access by non-U.S. Persons
    • sponsor has prior approval rights over publication content (review is acceptable)

  • Language in grant, contract, manufacturer, proposal or purchase documents that make specific reference to the International Traffic in Arms Regulations (ITAR) or Export Administration Regulations (EAR)​ (other than a general statement of compliance.

  • When purchasing equipment​ vendor asks for "End User Certification" or similar signed statement that buyer will not export or allow foreign national access to equipment.

  • Items or technical information produced for (or funded by) a defense, intelligence, or space related agency 
    • DoD​, Army, Air Force, Navy, NSA, DHS, DARPA, IARPA, NASA or similar

  • Research which involves:
    • development of technology or equipment (may be for civilian use)
    • defense, satellite, or space applications
    • encryption technology
    • biological or chemical threat agents and related medical remediation and diagnostics
    • receipt of proprietary information from a sponsor

  • Shipping or carrying controlled technology, equipment, or data overseas

  • International collaborations where controlled data is shared

  • Involvement with persons or entities from an embargoed or sanctioned country (Cuba, Iran, North Korea, North Sudan and Syria, others see OFAC Sanctions Programs)
  • Unsolicited requests by foreign nationals to visit high technology facilities

 

Please contact the Export Control Manager for a personal consultation if any of the above conditions apply (ovcrexportcompliance@wustl.edu). Even if there are no foreign nationals working directly on a project with export controls, a Technology Control Plan may need to be developed to protect controlled technology or data from unauthorized access (for example in an open-lab situation).