The University of Pittsburgh promotes and conducts research to advance knowledge, enhance student learning experiences, and build its reputation in the scientific community. While the University endorses the principles of freedom of inquiry and open exchange of knowledge, it is the policy of the University to comply with all laws applicable to research including export controls regulations.
The export of certain technologies, software and hardware is regulated and controlled by Federal laws for reasons of national security, foreign policy, prevention of the spread of weapons of mass destruction and for competitive trade reasons. The University and all its employees are required to comply with the laws and implementing regulations issued by the Department of State, through its International Traffic in Arms Regulations (ITAR), the Department of Commerce, through its Export Administration Regulations (EAR) and the Department of the Treasury/Office of Foreign Assets Controls (OFAC) through its Foreign Assets Control Regulations (FACR).
Due to increasing geopolitical pressures and foreign policy concerns, the security needs of the United States have been pushed to the forefront, rising to the highest priority. This means the importance and scrutiny of compliance with export laws and regulations have increased, and export control provisions are now routinely included in sponsored research contracts and other agreements with the University. It is important to emphasize that the export control laws and regulations do not just apply to research—the laws and regulations may apply to many types of activities and relationships that arise in the University setting.
Most research conducted on college and university campuses is classified as fundamental research where the resulting information and software is excluded from the export control regulations. However, university research involving specified technologies controlled under the EAR and/or ITAR, or transactions and exchanges with designated countries, individuals, and entities may require the University to obtain prior approval from the appropriate agency before: allowing foreign nationals to participate in controlled research; collaborating with a foreign company; or, sharing research—verbally or in writing—with individuals who are not United States citizens or permanent residents. The consequences of violating the export control laws and regulations can be quite severe, ranging from loss of research awards and export privileges to monetary penalties and jail time for the individuals who violate these laws and regulations.
In addition to research activities, the export control regulations apply to other different types of activities and relationships as well. For example, the export controls regulations apply to travel and shipping items outside the U.S. Simply traveling to certain sanctioned countries could require a license from the OFAC. In addition, OFAC issues sanctions which may prohibit transactions and exchange of goods and services in certain countries or with designated persons and entities. Multiple lists of denied individuals and parties are maintained and enforced by federal agencies including the Departments of State, Commerce, and Treasury. Shipping items outside the U.S. as well as taking controlled items on a flight, even if shipping or traveling to conduct research, could require a license from one or more of these agencies.
The University is committed to export controls compliance. The University has established the Office of Research Security & Trade Compliance (ORSTC) to serve as a resource and to support the University community in achieving export compliance. The University Export Controls Officer (UECO) resides in the ORSTC and is supported by multiple dedicated staff members. The UECO and staff are responsible for implementing the procedures laid out within this document. More detailed reference material and resources can be found on the ORSTC website or by contacting the UECO, at 412-624-7415, or e-mailing to researchsecurity@pitt.edu.