Licensing determinations are very complicated and can involve many different regulations. For assistance, contact ORSP staff (662-915-7482 or firstname.lastname@example.org); Mandy King, Director of Research Integrity and Compliance (662-915-5458 or email@example.com). For projects containing classified information, contact Dr. Mary Jourdan, Facility Security Officer (662-915-5006 or firstname.lastname@example.org).
The following steps cover most cases, but correct determination requires review of the facts and circumstances in each case.
- Determine whether the export is subject to U.S. jurisdiction. (U.S. universities are subject to U.S. jurisdiction as are any foreign nationals in the U.S.; overseas operations may be subject to U.S. jurisdiction).
- Classify the goods or technology involved as subject to ITAR, EAR, or other regulations.
- Determine whether a license is needed for the particular technology and particular end-use and end-user.
- Determine availability of license exemptions, e.g., public domain, fundamental research, etc.).
- Determine whether embargoes apply or whether any prohibited parties or destinations are involved.
- Determine whether there are any “red flags” or other warning signs of possible diversion of the technology.
If a license is required, apply promptly – licenses can take weeks or months to obtain.