Oklahoma State University (OSU) is committed to complying with all export control laws and regulations. As a faculty member, it is important that you understand how these requirements apply to you and your work at the University. As you know, it is a joint effort to ensure that you and OSU remain compliant, and I appreciate all your efforts in this area.
The Export Administration Regulations (EAR) overseen by the Department of Commerce and the International Traffic in Arms Regulations (ITAR) overseen by the Department of State are the primary regulations pertaining to export controls. The Treasury Department’s Office of Foreign Assets Control (OFAC) also has authority over some areas that impact export control issues and there are numerous Executive Orders that reference export controls. Recently, the EAR and ITAR have undergone major revisions, many of which are still on-going. I encourage you to review them. To do so, you may visit University Research Services website (https://urs.okstate.edu/exportcontrolforms), which provides links to the information and more details on this issue.
If your research efforts are specifically in areas involving ITAR-related technologies, which are inherently military in nature, you should know the University is currently not registered with the Department of State, Directorate of Defense Trade Controls, and at this time there are no plans to be registered. Therefore, if you are planning to pursue research funding on ITAR-related technologies, you must discuss this with your college research office and my office well in advance of the preparation and submission of any proposals.
It is unlawful to send or take export-controlled technology out of the U.S. or to disclose, orally or visually, or transfer export-controlled technology to foreign nationals inside or outside U.S. territory, without government approval. Technology is defined as “specific information necessary for the development, production or use of a product.” This applies to tangible technology such as field equipment, computers, smart phones, etc. that you may carry with you or ship abroad for your professional use.
Understanding the laws and regulations and how they apply can be confusing. Each item and/or project should be considered independently of others. I encourage you to familiarize yourself with the resources available. Ms. Jada Bruner Gailey, Director of Sponsored Programs, is available to help you understand export control regulations. Feel welcome to contact her at 405.744.9995 or firstname.lastname@example.org. If you are a department head or director, I encourage you to contact her and have her meet with you and your faculty/staff.