· Export of research products

· Certain oceanography or marine biology equipment may be controlled by ITAR

· Specially designed electronic components could be controlled

· Temporary transfer of research equipment abroad

· Carrying scientific equipment to certain destinations for research may require authorization (e.g., Iran, Syria, China, etc.)

· Software

· Software that is provided to the public for free may not require licenses, but proprietary software of controlled technology could require licensing

· Encryption technology could require licenses or could be prohibited for transfers to certain foreign nationals/countries

· Restrictions on certain foreign nationals

· March 2002 State Department rule expands fundamental research exemption for foreign nations involved in space-related research, but provides no relief for foreign nationals from certain countries (e.g., China) and creates oversight obligations  (e.g., U.S. entity must be responsible for what its European collaborator does with the information/technology)

· Government grants may limit access by foreign nationals

· Agencies may preclude or limit access by foreign nationals to research based on the export control laws

· Determining whether a restriction is a “specific access and dissemination control” under the ITAR (which would invalidate the fundamental research exclusion) may be problematic

· Corporate grants may limit access by foreign nationals

· Proprietary restrictions or restrictions on publication by corporate grants may invalidate fundamental research

· Could trigger licensing requirements for certain foreign nationals

· Conferences

· Potential restrictions on participants

· Inability to co-sponsor with certain countries or groups (e.g., restrictions on co-sponsoring conference with Iranian government)

 

MIT Office of Sponsored Programs

   Examples related to University Research