Export Controls & Sanctions Compliance

Export means to send, take or transmit an item or information outside the U.S., or to release technical data, technology or software source code to a foreign person, either within the U.S. or abroad.

Export controls are a group of federal laws and regulations that govern how certain items, services and information may be transmitted, taken outside the U.S., or shared with foreign nationals either within or outside the U.S. U.S. export control laws and regulations exist to maintain national security and protect U.S. economic vitality. The three main export control regimes are:

• Export Administration Regulations (EAR)
  The EAR are administered by the Bureau of Industry and Security under the U.S. Department of Commerce. The EAR regulate exports and re-exports of commercial and dual-use items, technology and software, as well as some less sensitive military items. Dual-use items have both commercial and military applications. Items subject to the EAR are listed on the Commerce Control List (CCL). A license may be required prior to export depending on the item, destination country, end-user and end-use.
• International Traffic in Arms Regulations (ITAR)
  The ITAR are administered by the U.S. Department of State. They govern the manufacture, export, and temporary import of defense articles, the furnishing of defense services, and brokering activities involving items described on the United States Munitions List (22 C.F.R. Part 121). Exports of ITAR items are subject to licensing requirements, unless a specific exception is met. No licenses are issued for certain countries, such as China.
• Office of Foreign Assets Control (OFAC)
  OFAC is the part of the U.S. Department of Treasury responsible for administering and enforcing economic and trade sanctions. To accomplish this objective, OFAC blocks assets of foreign countries subject to economic sanctions, controls participation in transactions with specific countries or nationals of such countries and administers embargoes on certain countries or areas of countries. Countries subject to significant economic sanctions or embargoes include, without limitation, Cuba, Iran, North Korea, Russia, Sudan, Syria, and Ukraine (certain regions). Transactions with sanctioned or embargoed countries may require licenses. For more information on OFAC, go to Economic Sanctions and Embargoes.

Yes, compliance is mandatory. The University of Kentucky and all UK personnel, including staff, faculty and students, must comply with export control laws and regulations. There are severe consequences to non-compliance, including civil and criminal penalties that could result in extreme fines or even imprisonment. Export control violations could additionally result in financial, reputational and strategic damage to UK and negatively impact UK’s ability to conduct important international activities.

Information regarding whether an activity is subject to export controls is available at the following links:

• Economic Sanctions and Embargoes
• Researcher Guidance
• International Shipping
• International Travel
• International Collaborations
• International Visitors

The chart in Appendix A (pdf) also may help you to identify whether an activity may be subject to export controls, and whether you should contact the relevant UK office set forth above for additional guidance and information.