Export Control Licensing

Licenses may be required to ship or transfer “controlled” technology, data or items to certain countries; to foreign nationals within the US or outside the US; to travel to certain countries; and/or to travel with certain items to certain countries. Applications for licenses MUST be done BEFORE the activity occurs. Licenses may also contain restrictive conditions. The process to receive a license can take 2-6 months or longer. There is no charge for a license; however, ITAR currently requires an annual registration fee of $1,750 per year (one time fee per year not per license request).

In general, a license may be required if:

  • Presentation/discussion of previously unpublished research at conferences and meetings where foreign nationals will be present.
  • Research collaborations with foreign nationals and technical exchange programs.
  • Transfer of research equipment overseas
  • Visits to your lab/facility by foreign scholars.
  • Transportation of laptops by faculty or students to foreign countries (includes personal OR business laptops)
  • Continuing Education – acceptance of payments from foreign nationals to enroll in courses requiring access codes (considered proprietary information)
  • Software – proprietary software, encrypted technology transmitted in any way.
  • Sales/Transfer of Technology – Transferring ownership of controlled articles to a foreign person in US or US citizen/entity abroad.

EAR License Requirements (Dual Use/Commercial Technologies)

  • “Terrorist Supporting Countries” such as Cuba, Iran, Libya, North Korea, Sudan and Syria
  • “Countries of Concern” such as former Soviet Republics, China and Vietnam
  • “Friendly Countries” such as all others (Europe, Central/South America, etc.)

ITAR License Requirements (Military/Space Technologies)

Policy of Denial

  • State Sponsors of Terrorism (Cuba, Iran, Libya, North Korea, Sudan and Syria)
  • Arms Embargo (Burma, PR China, Haiti, Liberia, Somalia and Sudan)
  • Others (Belarus, Iraq and Vietnam)

Policy of Denial Based on End-User

  • Afghanistan
  • Congo
  • Iraq
  • Rwanda