Do export control laws apply to me?

U.S. export control laws govern the transfer of controlled items and information/technologies to foreign countries and foreign persons for national security purposes. The regulations also seek to further U.S. foreign policy through the administration of trade and economic sanctions. Export regulations can control everything from physical items, technology, and data to economic transactions and business partnerships, including certain domestic activities. The University’s Policy on Export Controls states that all individuals or entities acting on behalf of the University must comply with all United States export control laws and regulations.

The UNC-Chapel Hill Export Compliance Program supports University operations by conducting compliance reviews for controlled activities. See the University Export Compliance Manual for additional details. View the Export Compliance in Research quick reference card to see a summary of where our program interacts with University operations and activities.

How can an export occur?

• Physically sending export-controlled items to a foreign country (international shipping).
• Hand-carrying export-controlled items to a foreign destination; this includes University laptops and other electronic devices taken on international travel.
• Transmitting export-controlled information or software electronically or digitally to a foreign location or foreign person, or accessing them from a foreign location.
• Use of export-controlled technology on behalf or for the benefit of a foreign person or foreign country.
• Deemed export – disclosure or transfer of export-controlled technology or software source code to a foreign individual or entity within the U.S. is deemed to be an export to the individual’s or entity’s home country. May occur via:
  • laboratory tours
  • involvement of foreign persons in the research
  • oral exchanges, emails, or visual inspection of equipment
  • hosting a foreign researcher.

Who can have access to export-controlled technology/information?

U.S. persons may have unrestricted access to export-controlled technology or information. A U.S. person is a U.S. citizen, permanent resident (“green card” holder), protected person, or an entity incorporated to do business in the U.S.

A foreign person may not be able to have access to export-controlled technology or information without an export license. The University’s Export Compliance Office should be consulted before granting access or sharing export-controlled technology or information with a foreign national or foreign entity.

Foreign persons include individuals holding a work, exchange visitor, or student visa (H-1B, H-1B1, O-1, J-1, or F-1), entities effectively owned or controlled by a foreign interest, and foreign businesses not incorporated in the U.S.