Federal regulations that impose access, dissemination or participation restrictions
on the transfer of items and information regulated for reasons of national security,
foreign policy, anti-terrorism or non-proliferation.
A university has an obligation to control the export of sensitive information outside
the borders of the United States.
Aid to embargoed or sanction countries can also be considered a violation of export
Certain controlled materials sent to a restricted country.
What is a "Deemed Export?" Examples?
An export of technology or sensitive information is "deemed" to take place when it
is released to a foreign national within the U.S., or possibly when that same information
is transferred to a foreign national's home country.
Examples could be giving certain information over the phone or a meal during conversation
to a foreign national, or giving a lecture at an international university which contains
sensitive information. What does the university do to comply with federal Export Control
The university has a multi-pronged approach. We screen all visitors coming to TTU
to see if they are a person of interest or investigation by the Federal Government.
For all TTU personnel traveling internationally, we screen their contacts for the
same federal interest.
What is the risk of violating export control regulations?
There are a variety of possible risks for violating EC regulations including loss
of funding, loss of visa programs, and even possibly jail time depending on the severity
of the violations.
What are EAR and ITAR?
ITAR stands for International Traffic in Arms Regulations and as its name implies
usually refers to items reserved for military or security use.
EAR stands for Export Administration Regulations and usually refers to more common
items. There are many examples of common items which are not allowed to be exported
from the US to certain countries.
What information does the university need to screen for EC compliance?
To properly screen, you must provide the following details:
Name of visitor/contact
Home country affiliation (university/organization/institute/company)
Dates of travel
Purpose of visit
Who needs to be screened for EC compliance?
Any international visitor to TTU should be screened. This includes, but is not limited
to, exchange students, research scholars, interns, delegates, job candidates, and
Any significant contact during international travel. This can be difficult to determine
sometimes, especially if faculty are traveling for different events. In those cases,
point of contact would be a conference organizer/chair, local travel arrangement team,
or local faculty and administrators.
Who on campus is responsible for EC compliance?
Jennifer Horn in the Office of the Vice President for Research (OVPR) handles EC issues
for research projects, funded research plans, and license applications. Visit - OVPR export control page
Michael Johnson in the Office of International Affairs (OIA) handles screening requests
for all inbound visitors to TTU. Emily Saiz handles screening requests which take
place via the International Travel Application.
When should screenings take place?
For TTU personnel traveling abroad, current Operating Policies state screenings should
take place 30 days in advance of travel.
For TTU departments hosting international visitors, contact our office as soon as
you become aware of the visitor. That will allow additional time should your visitor
encounter difficulties with invitation letters, visa appointments, etc.
How long do screenings take?
Under normal circumstances, EC screenings should take 2 business days or less.
How many times do I need to screen the same visitor/contact?
TTU only needs to screen an individual one time. After that, the system we use will
alert us if there is a change in that person's status. However, you should always
let our office know if that person is visiting again.
My travel/visitor came up as flag! Does that mean I can't go/host?
No. In many cases, even if someone is a subject of interest or investigation by the
federal government, your project may still be able to move forward, depending on your
proposed activity. In those cases, Jennifer Horn may need to apply for a license for
that situation. This will require additional information from you.
When did these new policies start and why?
In July, 2015, Provost Schovanec and then Vice President for Research Duncan sent
a letter to the university community discussing Export Control regulations and the
importance of complying with those federal laws. In that letter they discuss the role
of Export Controls when traveling internationally and when hosting an international
visitor. A copy of the letter can be found export control policies.
Is there an EC Checklist?
When traveling, make sure you complete your travel application 30 days before your
If hosting an international visitor, make sure you request EC screening for that visitor
at least 4 weeks before the intended visit. Additional information about hosting visitors
can be found at hosting international visitors.
If you plan to pay your visitor or reimburse them for their travel expenses, be sure
to visit our webpage on paying non-immigrant visitors as it has required information and forms necessary to complete that process.
Keep a copy of your EC screening result. This will be an email stating whether or
not there is a record of your visitor/contact and if you should proceed with your
endeavor. This email can be used as proof of completed screening.