Export Control at ISU
The term “export control” brings to mind shipping huge containers of food, clothing, machinery to a foreign country, mostly by sea-going vessels. While export controls certainly pertain to these situations, there are other circumstances that call for export control, especially at universities.
An export is “Any item that is sent from the United States to a foreign destination."
According to the U.S. Department of Commerce, "Items" include, "commodities, software or technology - such as clothing, building materials, circuit boards, automotive parts, blueprints, design plans, retail software packages and technical information.”
It is important to keep in mind that this definition includes “technology and technical information.”
Exporting includes sharing the ideas of this technology with those who are not US persons. This could happen at a conference in a foreign country or even in the hallway at ISU. After an action is determined to be an export, the next step is to determine if that item being shared is export controlled. If it is, you will need a license. The EC office can help you determine this and secure any needed licenses.
Most of the research conducted at ISU is considered fundamental research.
Fundamental research is “university research that carries with it no restrictions on publishing the results. Fundamental research has no export control restrictions. (The term fundamental research is not the same as basic research. Basic or applied research can both be fundamental research.)
To find out if your interactions with foreign persons or entities fall under export control, contact firstname.lastname@example.org.
We have assembled an ISU Export Control Manual which provides detailed information about export control at ISU.
Export Control Officer
Deb Easterly, EdD
Assistant VP Research Outreach and Compliance
Most ISU travelers heading to international destinations will have export control foreign travel review of their Chrome River pre-approval form.
Additional review may be needed if:
- You plan to take any equipment with you (includes ISU owned computers, UAV, cameras). Travel with personal devices – phones, tablets, computers, instrumentation – can trigger the same export control regulations as ISU equipment; or
- You are travelling to anywhere in China, Russia, Iran, Syria, Sudan, North Korea, or Cuba.
If either of these factors pertain, you must complete a Visual Compliance Travel Review Form.
The form will be reviewed by the ECO to determine if a license is needed or if a license exemption pertains.
Collaborations & Agreements
Please contact the Export Control Office as soon as you consider an international collaboration. This provides an opportunity to discuss related requirements when developing relationships with foreign persons and institutions.
ISU faculty and staff engage in activities related to research, instruction, healthcare, student outreach and other strategic partnerships and affiliations that may create obligations under United States export control regulations, the Foreign Corrupt Practices Act (FCPA), and economic and trade sanctions regulations.
As you consider partners, with universities, institutes, industry or individuals outside the United States, remember there are procedures that apply to these activities and interactions. Deb Easterly, ISU Export Control Officer and Assistant Vice President for Research Outreach and Compliance is your primary resource for these arrangements.
Contact Deb at (208) 282-2618 or by email at the Export Control mailbox at email@example.com or Robin Wilson, Research Compliance Analyst at (208) 282-1336.
If you have an item (physical item or technology) that has been determined to be export controlled and you want to export it, you will need a license. The ECO is the office that can apply for export control licenses. Work with the ECO as soon as you are aware you may need to export something.
In some cases, an export control license exception is available
To determine if a license is required, four questions must be answered:
- What is being exported (is it controlled and which agency controls it)?
- Where is it going or is it a deemed export?
- Who is receiving it and what is their citizenship?
- How will it be used?
Answering these questions will allow us to determine if you need a license and if you do, whether or not there is a license exception that can be used.
A license application and approval/denial can take up to six months for review before a final determination is made. A license for each foreign person and a separate license must be obtained for each project on which each foreign person is working.
The licensing process must be completed prior to beginning research on the project.
The Export Control Office, at the request and with the assistance of the principal investigator, will prepare and sign the necessary documentation for obtaining a license. The request should be submitted on the Export Assessment Request form. Individuals should not submit license applications on their own.
International Shipping and Purchasing
When you work with ISU Purchasing to purchase item, services, or materials from outside the US, they will screen the vendors.
If you are paying with a Pcard, contact Purchasing for a vendor screening before you conduct any transactions.
If you are shipping anything out of the U.S. be aware that there may be export control licensing requirements that you need to act on. If your item is export controlled you will need a license to ship it out of the country.
Contact ECO to determine what you need at firstname.lastname@example.org.
Not getting the needed permissions may cause your item to be held up at the border, going out of the country or coming back in.
Requesting Restricted Party Screen
Restricted Party Screening (RPS) is the process of having an individual, an organization, university or vendor checked against a set of official databases to determine whether or not they have any limits to ISU doing business with them.
Parties listed as "restrcited" there are debarred, ineligible for ISU to establish agreements with, exchange data or technology with, and/or ineligible to make purchases from for a variety of reasons related to the national interests.
To have a party screened for possible export control restrictions, provide the following information:
Company name Address (street and city) Country name
Website if known Requisition # or last 4 digits of P-card
Full name (no acronyms) Address (street and city) Country name
Website if known
Full name City and State Country name
Title Organizational affiliation if known
The Export Control Office uses Visual Compliance, a cloud-based tool, to perform these screenings. Once the RPS is complete, the requestor will be emailed the result. If this involves a purchase, email@example.com will be copied.
If the party’s status changes, ECO receives a notice and will update Purchasing to prevent future purchases and other ISU personnel as needed.
CONTACT: Robin Wilson, Research Compliance Analyst at (208) 282-1336
Or Deb Easterly, Export Control Officer at (208) 282-2618
Please use only the Export Control Office email: firstname.lastname@example.org