UK is committed to supporting international collaboration and welcoming international visitors. It is essential to comply with sanctions and export control laws when hosting and working with international visitors. Similarly, UK expects and requires that all international visitors abide by U.S. sanctions and export control laws and regulations during their time at UK.
When controlled material or technology is transferred or released to a foreign national in the U.S., it is a “deemed export” and treated no differently than exporting to that individual’s home country. Deemed exports include both tangible materials, as well as intangibles such as information, data and encryption. It is necessary to assess whether an export license is required for deemed exports.
While there may be additional considerations concerning foreign national students lawfully in the United States on relevant visa status, examples of when sanctions and export control regulations may apply to international visitors (i.e., non-U.S. person visitors) generally and their activities include the following:
- When a foreign national is participating in research that is not fundamental research
- When a visitor has access to or receives export-controlled information or technology
- When a visitor or their home institution is on a restricted party list
- When a foreign national participates in research or an activity subject to a Technology Control Plan.
- When a foreign national is from a country subject to a comprehensive sanction or embargo.
A U.S. person is:
- A U.S. entity or citizen;
- Lawful permanent resident (i.e., green card holder);
- Protected individual under the Immigration and Naturalization Act (8 U.S.C. § 1324b(a)(3) (i.e., temporary or pending residency status); or
- Any part of the U.S. government.