Although an export license will not be required for most international collaborations, it is vital to comply with sanctions and exports controls when collaborating with foreign nationals and foreign institutions. Factors to consider when analyzing whether your collaboration is subject to sanctions and export controls include the following:
International Collaborations
Does the collaboration involve an embargoed or sanctioned country?
Your collaboration may be subject to sanctions and export controls if you are collaborating with a foreign national or institution from an embargoed or sanctioned country, or if the collaboration otherwise involves an embargoed or sanctioned country under export control regulations. See Economic Sanctions and Embargoes.
In addition, you may not agree to comply, participate or cooperate with a boycott that is: (1) not sanctioned by the U.S., and (2) maintained by one foreign country against another. This includes the Arab League boycott of Israel but may also include other foreign boycotts.
Does the Fundamental Research Exclusion (FRE) apply?
No deemed export license is required for research covered by the FRE. However, a license may be required where the research activity falls outside the coverage of the FRE. For example, the FRE does not apply to a restricted or prohibited individual or entity, e.g., under OFAC restricted situations. For more information, see Researcher Guidance. The FRE does not apply to research conducted outside of the U.S.
Is the collaborating institution or individual on a restricted or prohibited list?
Always verify whether your collaboration involves any persons or entities on a restricted party list.
Will the collaboration involve shipping or carrying items to foreign persons or a foreign entity outside the U.S.?
- If you are planning to ship an item to a foreign person inside or outside the U.S., or to a foreign institution outside the U.S., refer to International Shipping.
- If you are planning to travel outside of the U.S., please refer to International Travel.
- Consult the consult the EAR Commerce Control List (CCL) and the U.S. Department of State’s Munitions List (USML) to assess whether an export license is required for a particular item.