U.S. Export Controls and Economic Sanctions
The University of Nevada, Reno, is committed to complying with U.S. laws and regulations regarding export controls and economic sanctions. The information below is designed to assist the University community with understanding the complex environment of these laws. It is the goal of the Office of Sponsored Projects to provide training and guidance concerning the application of these laws to University activities. The University seeks to balance its commitment to the principle of openness in research and education with its obligations under these laws and regulations.
U.S. export control and economic sanctions regulations exist to protect national security, foreign policy and domestic economic interests. Export control regulations identify items, software, technology and services that may require an export license to transfer out of the U.S. Additionally, the release of controlled technology to a foreign national inside the United States is considered to be a "deemed export" to the individual's home country and is subject to the same regulations.
Similarly, economic sanctions programs prohibit transactions with certain countries, institutions, and individuals in order to accomplish foreign policy and national security goals. Prohibited transactions are trade or financial transactions, and other dealings such as providing services, in which U.S. persons may not engage unless authorized or expressly exempted by statute.
Export controls usually arise for one or more of the following reasons:
- The nature of the export has actual or potential military applications or economic protection issues
- Government concerns about the destination country, organization, or individual
- Government concerns about the declared or suspected end use or end user of the export
Several federal agencies are responsible for export control laws. Primary jurisdiction resides with the Departments of State, Commerce, and the Treasury. Other regulatory agencies with export controls relevant to UNR activities include the Departments of Agriculture and Energy, and the Nuclear Regulatory Commission.
Violations of export control and economic sanctions regulations can result in the loss of research contracts, as well as both civil and criminal fines and prison sentences. When in doubt if these regulations apply to your activity, please contact the Office of Sponsored Projects.
What does the University export?
The University exports every day. We export ideas and information (technology) through innovation, creation, and sharing with students, staff, colleagues, and visitors on campus and in our research labs. Every time we ship or travel internationally, we export equipment, technology and knowledge.
Common activities that may include export control or economic sanctions considerations include:
- Payments and receipt of of compensation, honoraria and contracts;
- Attendance at, or planning of, international conferences;
- Involvement of foreign students or collaborators in research in which controlled technology is used;
- Shipping or disseminating controlled items or information internationally;
- Provision of services to foreign nationals, including training in the use of controlled equipment in or outside the United States.
Exclusions and Exemptions
Recognizing the importance of academic freedom and the sharing of research results to the furtherance of knowledge, the federal government has excluded certain kinds of information from export controls. The vast majority of the University's activities are excluded from export control and economic sanctions regulations. Export control regulations generally do not apply to information that is 1) in the public domain/publicly available, 2) released in academic catalog-listed courses, or 3) the result of Fundamental Research. Because there are exceptions to these exclusions, always consult with the Office of Sponsored Projects if there is uncertainty about the export control status of any University activity.
In certain situations, activities controlled for export may be allowed without a license if a license exception applies to the activities. The conditions for license exceptions can be very narrow and must be strictly adhered to. The use of license exceptions must be documented by the Office of Sponsored Projects and records kept for a minimum of five years.
To determine whether your project may be subject to export control and economic sanctions regulations, view the University Export Control Checklist as well as the Export Control Policy. If in doubt, please reach out to the Office of Sponsored Projects for advice and assistance. We are here to support your learning, discovery, and innovation!
Export Controls Training
Training on export controls and economic sanctions is available through the web-based Collaborative Institutional Training Initiative (CITI) modules for Export Control. Click her for directions for accessing the CITI training in U.S. Export Controls.
Individuals or departments may request in-person training by contacting the University's Export Controls Officer, Michele Dondanville, at (775) 784-6360 or firstname.lastname@example.org.
Export Controls Frequently Asked Questions
For additional information about export controls, please see the Export Control FAQ.
Foreign Workers and Visitors
An export controls and economic sanctions evaluation is required for foreign workers and visitors coming to the University on the following visa types: H-1B, J-1 Research Scholar, J-1 Professor, J-1 Short-Term Scholar. Departments should complete the Export Control Evaluation for Foreign Workers and Visitors (OSP-30) form, submit it to the Office of Sponsored Projects for evaluation, and then submit the fully signed form with the rest of the visa application paperwork to the Office of International Students and Scholars. An export control evaluation is not required for J-1 or F-1 Students.
Departments hosting foreign visitors for any reason may request the Office of Sponsored Projects to run a Restricted Party Screening by submitting the OSP-30 form.
Prior to shipping anything out of the United States, it is important to know the following:
- What is being shipped - do export controls apply?
- Where is it going - are there restrictions, sanctions or embargoes on the destination?
- Who will receive it - are there any prohibitions on the end user?
- What will it be used for - are there any prohibitions on the end use?
Answers to these questions will indicate whether or not you need a license to ship. If the answer is "no" to all of the above, you will likely be able to ship "NLR" (No License Required). If you have any reason to believe that export controls or economic sanctions may apply, contact the Office of Sponsored Projects prior to shipping. If a license is necessary, it will take time to process; please plan accordingly.
Export controls and economic sanctions are particularly important when traveling outside the U.S. If you are planning international travel, please click here for more information.