Reminder Regarding Iran-related U.S. Sanctions Regulations
Memo from the Senior Vice Provost for Research
Export Control Laws and Regulations
Export control laws (ECLs) are a complex set of federal laws and regulations designed to protect U.S. national security; to prevent the proliferation of weapons of mass destruction; to further U.S. foreign policy including the support of international agreements, human rights and regional stability; and to maintain U.S. economic competitiveness. ECLs govern how information, technologies, and commodities can be transmitted to anyone internationally, including U.S. citizens, or to foreign nationals in the United States, and prohibit the unlicensed export of certain items and services.
University research is subject to ECLs, including the International Traffic in Arms Regulations (ITAR), implemented by the U.S. Department of State, and the Export Administration Regulations (EAR), implemented by the U.S. Department of Commerce. The Office of Foreign Asset Control (OFAC), which is part of the U.S. Department of the Treasury, is responsible for administering and enforcing economic and trade sanctions against certain nations, entities, and individuals. While most research conducted on campus will not be subject to export control restrictions, ECLs can apply to many Penn-related activities, such as: the temporary export of University-owned equipment, including laptop computers containing controlled software or technical data; shipment of research materials to foreign collaborators; hosting international visitors; international travel or collaboration involving sanctioned or embargoed countries; as well as certain research activities here on campus. Failure to comply with export regulations can result in severe consequences for the University of Pennsylvania as well as the individual researchers, including fines of over $1 million per violation, up to 20 years imprisonment, and debarment from future exporting activities.
Export Compliance Support at Penn
The Office of Export Compliance in the Office of Research Services helps Penn researchers and staff remain in compliance with these laws and regulations. We are here to help navigate export compliance issues as they arise, assist in determining when the regulations are applicable and if an export license may be required, and apply for licenses as necessary.
If you have questions about whether these regulations impact your work, please email email@example.com or contact the Director of Export Compliance, Jessica Buchanan, at firstname.lastname@example.org or 215-573-8817.
Penn’s Office of the Vice Provost for Research provides general guidance on engaging in global research on their website. Additionally, the following information and resources are available to help you learn more about the issues surrounding export controls and how the regulations apply to Penn-related activities.
Review Global Research Guidance
Important resources for researchers working with international partners
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