Export Control

On this page:

Overview and Institutional Commitment

Export Controls are a series of federal regulations that govern the export of sensitive materials, technology, or software in order to protect national security or foreign policy objectives. Wright State University’s policy is to fully comply with all requirements of the US export control laws that apply to activities at Wright State.

Policy

Policy on Export Controls and Trade Compliance (University Policy 6150).

General Information/Guidelines

International Travel and Export Compliance

International Travel is a necessary component of a busy and engaged higher education institution. There are many precautions that can and should be made prior to one’s trip. Export Control laws may impact your ability to travel to or through certain countries, the technology you take with you, or the information you present abroad. Please contact our office at least two months in advance of international travel when there is a potential for a regulated export.  

Pre-Approval of Travel and Emburse/Chrome River:  When travel is international and includes research activities (e.g. (a) the collection, presentation, or sharing of data or results; (b) research collaboration;  or (c) the physical transport of regulated materials), institutional pre-approval is required, and Export Compliance issues must be addressed. Factors considered during the review include the destination and waypoints, the traveler's field of study, and the specific purpose of the travel.  In some cases, even though the researcher's field does not typically include the technologies subject to Export Control regulations, devices (computers, iPhones, etc.) that use encryption technology may be subject to seizure or to the copying of their contents at the border.  Penalties for unapproved exports of controlled materials or information can be significant for the traveler.   

Procedure: You will be required to obtain pre-approval and approval for all travel expenses.  Submission of information and approvals is managed through Emburse/ChromeRiver.  If you are traveling internationally, the Export Control Officer is included in the approval routing.

If your travel includes research or your field involves potential Research Security or Export Control concerns, you may be asked to provide additional information.  You will be contacted and asked to complete and submit the form linked below. If you know or expect you will need to provide more information, you may download and complete the form linked below, then upload it during the Chrome River Expense/Pre-Approval process.  

       Export Compliance Travel Screening Form
 

Technology and Travel:  Faculty and staff of Wright State working or conducting research while traveling should consider traveling with devices that do not contain sensitive or irreplaceable information.   Your Wright State devices may allow unauthorized persons to access the WSU network as well as your data.   

Training

Forms

Frequently Asked Questions

  • Who needs to be aware of export control (EC) restrictions?

    All faculty, staff and students would benefit from an awareness of export control restrictions. Sign up for an in-person training session or take the export control courses available through CITI 

  • What types of transactions or activities fall under EC restrictions?

    Many different types of activities can be impacted by export control laws, especially:

    • Dept. of Defense funded research
    • International travel
    • International shipping and receiving
    • Distance learning
    • Foreign visitors/Visa
  • How do I know if I should be concerned?

    Review our Export Control webpage and resources or contact us at exportcompliance@wright.edu

  • If I am travelling within the United States do I need to do anything specific?

    No. Travel within the United States does not create an export control concern.

  • If I am travelling internationally, what should I do?

    Register your travel in the Chrome River system as soon as possible. Contact CaTS to utilize their clean laptop and cell phone program.
     

  • Are there international destinations that are more problematic?

    Yes, travel to Iran, Cuba, North Korea, Syria, and the Crimea region are comprehensively sanctioned countries and require special government authorization before traveling. It can take more than six months to get permission, so contact the export compliance officer as early as possible.

  • I want to collaborate with international faculty members on a project. How should I proceed?

    Collaborations with comprehensively sanctioned countries (Iran, Cuba, North Korea, Syria, and the Crimea region) and/or military technologies are problematic but the majority of international collaborations will not have EC issues. To be safe, please contact our office to briefly discuss your ideas.

  • Are there any exceptions to EC rules for universities?
    1. Fundamental research – This exclusion is based on National Security Decision Directive 189, which defines “Fundamental Research” as: “Basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community, as distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons”
    2. Public Domain - The ITAR and EAR each have specific definitions of what constitutes “public domain.” However, the general intent is that information is not subject to control once it has been published (lawfully) or made generally available to the public through means such as public libraries, published patents, release at open conferences, and publishing on an open website.

Contact Information

Neal Sullivan, Ph.D.
neal.sullivan@wright.edu, 937-775-3418