Export Control (EC)

U.S. export control regulations affect a wide range of research and academic activities at Emory including conducting restricted sponsored research, engaging in international collaborations, hosting international visitors or visiting scholars, international travel, employing foreign nationals (nonimmigrant employees), and shipping. Engaging in these activities can result in actual or deemed exports that may require Emory to obtain an export license. Non-compliance with export regulations can result in severe penalties for both Emory and individuals including criminal and civil liability, loss of export privileges, and the potential loss of research funding.

Emory’s Export Control Office (ECO) is responsible for administering Emory’s export control compliance program. The ECO helps Emory remain compliant by developing administrative processes, designing tools, providing training, and serving as a resource for departments, faculty, and staff.

Because export control regulations are complex and regularly updated, information on this website may not be comprehensive. Please email the Export Control Office with questions or for additional information.

Meet the Team

About Export Controls

Export controls refer to federal laws and regulations that govern how certain items (information, technologies, and commodities) can be exported from the United States or shared with Foreign Persons in the United States. The laws and regulations are designed to protect national security, economic interests, competitiveness, and foreign policy of the United States. The regulations include:

Compliance with U.S. export controls is not optional, and the consequences of non-compliance can be severe. Civil and criminal penalties can result in steep fines and even imprisonment. Export control violations can mean financial, reputational, and strategic damage for Emory and can affect Emory's ability to conduct important international activities in the future. As a U.S. research and academic institution, Emory and its personnel, including faculty, staff, and students, are required to comply with regulatory requirements related to export controls.

This list is not exhaustive, but here are some indicators of when an export compliance review is necessary. See Policies & Guidelines for additional information.

  1. The sponsor indicates that the research is export-controlled or is classified.
  2. The results of the research are intended for military purposes or for other restricted end-uses or users.
  3. Foreign Persons will have access to export-controlled technology or technical data on campus.
  4. Emory faculty or staff will export or travel abroad with research equipment, chemicals, biological materials, or encrypted software; laptops, cell phones, or PDAs containing export-controlled information; or other export-controlled items.
  5. A proposed activity or transaction will involve embargoed countries; embargoed entities; individuals or entities located in embargoed countries; or individuals or entities who are on prohibited or restricted end-user lists as determined by Restricted Party Screening.
  6. The sponsor requires the right to approve publications or restricts the participation Foreign Persons.
  7. The project requires shipping equipment, chemical, or biological materials to a foreign country.
  8. The agreement contains a Controlled Unclassified Information (CUI) clause or other data security and access clause.

Foreign Person: Any natural person who is not a lawful permanent resident of the United States, citizen of the United States, or any other protected individual as defined by 8 U.S.C. 1324b(a)(3). It also means any corporation, business association, partnership, trust, society or any other entity or group that is not incorporated in the United States or organized to do business in the United States, as well as international organizations, foreign governments and any agency or subdivision of a foreign government (e.g., diplomatic mission). "Foreign Person" is synonymous with "foreign national," as used in the EAR, and "foreign person" as used in the International Traffic in Arms Regulations (22 CFR 120.16).

Export: Transfer of items, (technology, software, or technical data) out of the U.S by any means (electronic, verbal, shipping etc.) Export includes the concept of "deemed export" (see below).

Deemed Export: Release or disclosure within the U.S. of controlled technology (or technical data) or software source code to a Foreign Person. Deemed re-export occurs when such release is occurs outside the U.S.

Release: Technology or software is released through visual or other inspection by a Foreign Person of items that reveals controlled technology or source code. Release can also occur via oral or written exchanges with a Foreign Person in the United States or abroad.

See Definitions for other export controls definitions.

Complying with regulatory requirements is vital. It is equally important that Emory continue to maintain its collaborative research environment, both domestically and internationally, because they are essential to Emory's scholarly mission. Export control laws and regulations are complex and are revised and updated constantly. The objective of the Export Controls Compliance Program (ECCP) is to reduce the institutional and individual risk of export controls violations. The Export Control Office is responsible for development, implementation, monitoring, and coordination of the ECCP and provides necessary support, information, and tools to Emory's research enterprise to ensure compliance.

Report an Event

Emory personnel can contact ECO directly (exportcontrol@emory.edu) to report any suspected violations. The Integrity Hotline is also available for confidential reporting. Given the seriousness of export control violations, Emory takes steps to detect and address potential issues in a timely manner.