What are Export Controls?
- 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 controls.
- 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 regulations?
- 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
- Most recent home country affiliation (university/organization/institute/company/high school)
- 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
- Currently, best practices does not require that we screen traditional degree-seeking students (F-1 students).
- Permanent Residents (green card holders) are treated as U.S. citizens and do NOT need to be screened for EC compliance.
- 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.
- Departments who wish to pay or reimburse an international party must first establish the party as an international vendor. Please email TechBuy to initiate the requirements for the procurement/payment process. Export Control compliance screening will be conducted as a part of that process.
Who on campus is responsible for EC compliance?
- Jennifer Horn and William Wells in the Office of the Vice President for Research (OVPR) handle 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.
- For TTU departments wishing to pay or reimburse an international vendor, please email TechBuy within Vendor Services as soon as possible to start that process.
How long do screenings take?
- Under normal circumstances, EC screenings within this office 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.
Do we need to screen Permanent Residents (PRs)?
- Negative. Permanent Residents possess a green card and are treated the same as United States citizens for the purposes of Export Control compliance screening.
Is there an EC Checklist?
- When traveling, make sure you complete your travel application 30 days before your intended travel.
- 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.
Please click the button below to submit an Export Control screening request for international visitor(s) to Texas Tech University.
Export Control Screening Request