Brown’s export control compliance program is designed to limit Brown’s exposure to products, technology and technical data controlled by International Traffic in Arms Regulations (ITAR). Brown's policy presumptively prohibits faculty, students or staff from purchasing or receiving any item that is listed on the U.S. Munitions List (USML) and subject to ITAR, unless prior documented approval is received from the vice president for research. 

It is critically important for University personnel to be able to identify when activities may trigger export controls and reach out to the Export Control team with questions or to get assistance. Personnel also should follow internal procedures for shipping, visitor screening, international travel and purchasing; take the appropriate steps to ensure governmental licenses are obtained; monitor and safeguard access to restricted information and controlled materials; and complete any requisite training.

• Export Control and U.S. Economic Sanctions Policy
• Brown University Export Control Compliance Manual [PDF]

The Export Control team, part of Research Integrity, helps members of the Brown community comply with export control laws and policy. The Export Control Officer and other staff collaborate with departments across campus to carefully evaluate proposed transactions and determine whether they fall on the USML or Commerce Control List (CCL), screen transactions for involvement with restricted parties and facilitate the export license application process. They also provide a variety of training programs. 

The Export Control team works with departments to ensure compliance with federal regulations by providing review of the following research activities:

• Grants and agreements — Export Control works with Sponsored Projects and Brown Technology Innovations to ensure that all incoming research agreements are reviewed for potentially restrictive publication or participation clauses.
• Incoming legal agreements and contracts — Export Control works with the Office of General Counsel (OGC) and Research Contracts and Agreements (RAC) to ensure that incoming legal agreements and contracts are reviewed for export control compliance requirements and anti-boycott clauses.
• Purchase of equipment, technology and software — Export Control collaborates with Strategic Procurement and Contracts to review and classify certain purchases to be made via a purchase order.
• Material transfer agreements — Export Control works with RAC to review language for incoming material transfer agreements (MTAs) and to screen materials being shipped internationally by Brown personnel under an outgoing MTA.
• Biological materials for shipping — Export Control works with Environmental Health and Safety (EHS) to resolve any potential “hits” that EHS may encounter as it screens biological materials being prepared for shipment.

International travel and collaborations — Export Control receives alerts from the Internal Review Board and from Sponsored Projects regarding studies that involve international travel or international collaborations. The team screens potential international collaborators and provides the principal investigator with additional information regarding export controls.

Contact Export Control

Required Contact

Per Brown’s policy, you are required to contact and work with the Export Control in the following situations:

• You plan to travel to a comprehensively embargoed country.
• You plan to purchase or receive technology, technical data or materials that are listed on the USML and are controlled under ITAR.
• You are asked by a funder or research collaborator to perform classified or unclassified-restricted research. (Note: Brown does not accept classified research on its campus.)
• You receive a collaboration or nondisclosure agreement from a third-party research collaborator that contains references to “export controls” or “controlled technology or data.”
• You receive a request (verbal or written) from a research sponsor or program officer that restricts dissemination of research results, requires publication pre-approval by the sponsor or limits involvement of foreign nationals.
• You receive a request (verbal or written) or agreement/contract that supports a restrictive trade practice or boycott imposed by another country. In this case, you must report this to the Export Control team, which in turn is obligated by law to review and, when required, report it to the U.S. Department of Commerce.
• You develop or build new technology for primary military applications. 
• You plan to provide online instruction or courses, including via massive open online courses, to students in comprehensively embargoed countries.

Research Activities Impacted by Export Controls

Recommended Contact

While you are encouraged to contact the Export Control team at any time with questions, the following are situations in which you should definitely seek assistance:

• You travel outside the U.S. with technology or encrypted devices and are not sure whether that technology or encrypted device requires an export license.
• You wish to ship research materials and technology abroad and are not sure whether the materials and technology require an export license.
• You plan to travel to a country with a limited sanctions program.
• You are hosting visiting scholars, scientists, students or trainees from comprehensively embargoed countries.
• You are working with groups or organizations that may be on a restricted party list, such as current and former rebel groups, current and former terrorist organizations, members of current or former dictatorships or undemocratic regimes.
• You are purchasing special research equipment that may be highly restricted. If vendor quotes or sales agreements contain references to “export controls,” ITAR or Export Administration Regulations (EAR), contact the export control compliance team for assistance.

Navigating export controls can be very complex, and determining if and when your activity or research may require an export license is not easy. Brown provides one-on-one consultations, as well as group training, to help faculty, students and staff navigate export regulations within the University environment. Brown also offers online export control training for users with access to TrainCaster. Email exportcontrol@brown.edu for more information. 

The Brown University Export Control Advisory Group meets semi-annually, or more frequently if necessary. The group provides guidance to the Vice President of Research, Research Integrity and Export Control team regarding export control issues at Brown University, including but not limited to assisting with the development of policies, guidelines, procedures, training programs pertaining to export control, and facilitating communication and dissemination of information about export control compliance to the Brown community. 

The advisory group comprises representatives from the Brown research community as well as representatives from the following University offices:

• Office of General Counsel (OGC)
• Export Control (part of Research Integrity)
• Sponsored Projects
• Brown Technology Innovations (BTI)
• Environmental Health and Safety (EH&S)
• Office of International Student and Scholar Services (OISSS)
• Strategic Procurement and Contracts (SPC)
• Research Strategy and Development (RSD) 
• Facilities Management

Faculty and others with a vested interest in shaping the future of the export control compliance program at Brown are encouraged to contact Export Control to learn more about serving on the advisory group.