US Export Control Laws and Research at WUSTL
Washington University is committed, as stated in its Code of Conduct, to comply with all applicable Federal laws and regulations. Export control regulations, including the Export Administration Regulations (EAR) controlled by the Department of Commerce, the International Traffic in Arms Regulations (ITAR) managed by the State Department, and the sanction regulations governing the transfer of assets governed by the U.S. Department of Treasury through its Office of Foreign Assets Control (OFAC), directly affect the activities of University researchers. Penalties are severe for non-compliance, including monetary and criminal punishment for both the institution and the individual PI.
It is the position of the Vice Chancellor for Research that the Office of the Vice Chancellor for Research shall proactively address export control regulation compliance in partnership with the appropriate offices within the University, including, but not limited to, the Office of General Counsel and the Office of Environmental Health and Safety. The Office of the Vice Chancellor for Research will (1) maintain compliance with export control laws within sponsored projects administration, (2) educate researchers and department, school and central research administrators on export regulation compliance, and (3) provide a central point of contact for information and assistance in compliance for the University’s research community. Proposals, research agreements and material transfer agreements under the administration of the Vice Chancellor for Research shall be reviewed for export control compliance. In addition, the VCR shall proactively assist deans in the oversight of research conducted without external funding.
Restrictions on the use of foreign nationals in program requirements or contractual requirements impose stringent obligations on the University, including restrictions of access to laboratories and research data. Thus, such clauses generally are not consistent with the University’s policies on openness in research and nondiscrimination and will not be accepted. Requests for exceptions to these policies should be submitted to the Office of the Vice Chancellor for Research. Exceptions are considered in consultation with the appropriate department head and dean. In any case where a license is required by law, the activity or research will not commence until the license is obtained.
For more information about export controls, please contact Nathan Collins, Export Control Officer, ph. 935.7551 or visit the University export controls website.
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Educational Presentation: Export Control Laws & Washington University