Export Controls

The HU Export Control Program ensures compliance with U.S. export control laws and regulations. These laws govern the export of sensitive equipment, software, and technology to promote national security and foreign policy objectives. The program aims to prevent unauthorized access to controlled items and technologies, particularly by foreign nationals, and to ensure that research activities do not inadvertently violate export control regulations. The program includes the Export Control Committee, which reviews and research research protocols and sponsored projects that include an international component or other export concern.

Export Control Committee

The Howard University Export Control Committee is the institutional review board that is responsible for overseeing and ensuring compliance with U.S. export control laws and regulations. Export controls and trade sanctions are the United States laws and regulations that regulate and restrict the release of critical technologies, software, equipment, chemical, biological materials and other materials, and services to foreign nationals and foreign countries for reasons of foreign policy and national security.

The Export Control Committee:

• Ensure all research activities comply with U.S. export control laws, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).

• Identify and assess potential export control risks in research projects and implement measures to mitigate these risks.

• Conduct regular monitoring and auditing of research activities to ensure compliance and address any issues promptly.

Membership

The Howard University Export Control Committee is comprised of

• Chairpersons of the other regulatory compliance boards and committees

• Practicing scientists from various Howard University academic units who are experienced in research.

Meetings

The Export Control Committee meets on an ad hoc basis, when export control concerns require discussion.

What is Considered an Export?

Federal export control laws restrict the export of goods, technology, related technical data and certain services in the interest of protecting the national security and domestic economy. These laws have been in existence for many years, but the events of 9/11 have resulted in heightened concerns about national security and stricter interpretation and enforcement of export control laws and regulations by the federal government.

Federal export controls are enumerated primarily through the Export Administration Regulations (EAR, implemented by the Department of Commerce for items that have both a commercial and potential military use) and the International Traffic in Arms Regulations (ITAR, implemented by the Department of State for military items and defense services.) The Treasury Department's Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions to protect foreign policy and national security goals.

An export is:

• Shipment of a controlled commodity, equipment, material, or software outside of the U.S.
• Disclosing controlled technology or technical data to a foreign national, whether in the U.S. or abroad
• Performing technical assistance or defense services for or on behalf of a foreign national, whether in the U.S. or abroad
• Exports within the U.S. are considered to be a "deemed" export to the foreign national's home country