Export Controls

As described in System Policy 15.03 Export Controls and the related University Rule 15.03.01 Export Controls, export control laws and regulations restrict or prohibit the transaction of business with certain countries, persons and entities that have been sanctioned by federal agencies as a threat to important U.S. interests.

As a result, employees may be prohibited/restricted in their ability to transact business with individuals and entities appearing on Restricted Party Lists or from sanctioned/embargoed countries (i.e. Iran, Sudan, Syria, North Korea, Cuba, Crimea Region of the Ukraine, as well as other countries).

Texas A&M uses export control software to screen vendors against Restricted Party Lists.

Using a payment card to purchase or transfer “export controlled” technology, software, information or items may also be prohibited or restricted.  Lookout for some of these red flags:  classified, controlled, military, nuclear material, avionics, propulsion, chemicals, biologicals, toxins, pathogens, microorganisms, and international shipping.

Export controlled technology, software, information or items generally involves “dual use” technologies and defense articles listed on Commerce Control List and the U.S. Munitions List.

The following list illustrates, by example, some types of potentially controlled equipment:

• Night vision goggles, infrared cameras, military electronics, radar applications
• Sonobuoys and deep oceanic position signaling devices
• GPS, Inertial navigation systems, Gravimeter, Wind tunnel apparatus

Measuring and sensing devices, Gas movement and filtering devices, Ocilloscopes; spectrometers, fermenters

• Precision tooling, positioning and balancing instruments
• Optical and photonic components (including sensors, infrared and focal plane array detectors)
• Nuclear/radioactive transport or shielding equipment
• Class 3 and 4 lasers, and related precision beam equipment
• Semiconductor substrate and etching development equipment and processes
• Fiber optic cable development equipment

Marine submersible equipment (including hydrophones, signal receiving/emitting devices, pingers, acoustical releases submersible video and television apparatus, etc.), submersible vessels

• Unmanned aerial vehicles (drones), Remotely operated vehicles (ROVs)
• Encryption software

If you are procuring the types of commodities listed above, request the export control classification (ECCN) from the vendor.  Then work with the Export Control Office to implement control measures, as necessary.

If your transactions involve any of the red flags, work with your department and the Export Control Office to ensure compliance.

For guidance on specific questions, contact the Office of Research Compliance and Biosafety’s Export Control Office at 979-862-6419 or via email at exportcontrols@tamu.edu.  Export control tools and resources are available on the Office of Research Compliance and Biosafety website at http://rcb.tamu.edu/exportcontrols.