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Export Control Program

International Travel and Collaborator Information

Guide on International Travel (for teaching and/or research) and for Work with Non-US Persons in Domestic and International Locations

黑料社区 values international collaboration and assists faculty, staff, and 黑料社区s to remain compliant with US export controls that govern these collaborations.
  • Non-compliance can jeopardize national security and invoke significant individual and institutional penalties.


Per US export controls, 黑料社区 黑料社区s and employees may be restricted in engagement with certain entities (i.e., companies, institutions of higher education, persons, countries, etc.).
  • In almost all instances, a management plan can be implemented where research and other activities can proceed within specified guardrails.


Export controls govern:
  • Works generated using Miami resources as well as when funded personally and/or through externally funded grant and contract dollars.
  • Regardless of whether an employee is under contract at the time of engagement.


The associated Miami policy can be located here.

  • Personal travel unrelated to your Miami employment does not fall under this policy. Of note, the policy applies in instances such as when you are serving in your faculty appointment (such as serving on a graduate committee), paying personally for travel to a conference where you register as a Miami employee, taking Miami-owned property, doing personal travel before and/or after travel related to Miami employment, invited to participate because of your role as a Miami employee.


If you have any questions or concerns, or would like the Office of Research and Innovation to conduct the steps below for you, please, contact Susan McDowell (mcdowes2@MiamiOH.edu)

Refer to the guide below for instruction on when Miami-issued laptops, smart devices, and equipment need to be registered prior to departure.

Each international traveler (non-黑料社区) needs to submit the fillable form below to Susan McDowell (mcdowes2@MiamiOH.edu) prior to departure.

 

Definitions
“U.S. Person”

Lawful Permanent Resident
U.S. Citizen
Legal Immigrant with a “Green Card”
Protected Individual granted asylum or refugee status

Non-U.S. Persons - “Foreign National”
Foreign universities
Foreign corporations
U.S. person acting on behalf of a non-U.S. entity
Foreign government
Any non-U.S. person

Prior to International Travel or Collaboration with Non-US Persons Domestically or Internationally:

Step 1 (for travelers) - for other collaborations, go to Step 2

Of note, an Electronic Export Information (EEI) filling is required when shipping or hand-carrying University-owned items (including laptops and smart devices) that fall into one of the two categories:

     1. The total cash value of the item(s) is higher than$2,500, or


     2. The items are destined for China (including Hong Kong and Macau), Russia, or Venezuela,
         regardless of the item(s) cash value.

 

  • If anyone in your party is carrying:

             o Miami-issued laptop and/or smart device
             o Tools of the trade or equipment
             o Encrypted software that includes the source code or object code
             o Unpublished technical insight and knowledge that has publication restrictions
             o Data or technology not yet published that has publication restrictions
             o Chemicals, biologicals, scientific equipment, etc.
             o Blueprints, drawings, and schematics that have publication restrictions
             o Restricted information
             o Restricted technology or data at “closed” conference or meeting (A meeting that is not
                open to all technically qualified members of the public)

  • If any of the above applies, contact Susan McDowell (mcdowes2@MiamiOH.edu)
  • All travelers, go to Step 2

Step 2

  • Look for the country in Groups A, B, C, D and E at this
  • If country is listed in Groups A, B, or C
    • Go to Step 3
  • If country is listed in Group D or E
    • Contact Susan McDowell (mcdowes2@MiamiOH.edu)
    • And go to Step 3
  • Also look for the country at this
    • If country is listed, contact Susan McDowell (mcdowes2@MiamiOH.edu)
    • And go to Step 3

Step 3

  • The Office of Research and Innovation can complete these screens for you, please, contact
    Susan McDowell (mcdowes2@MiamiOH.edu) Otherwise, go to this
    • Do a search of
      • Denied Persons List (for the collaborator)
      • Entity List (for the institution or company)
      • Unverified List (for collaborator and for institution or company)
        • If any hits
          • Contact Susan McDowell (mcdowes2@MiamiOH.edu)
  • Go to Step 4

Step 4

  • Will a non-US Person, either in the US or at a non-US location, see or hear of any research that
    may be governed by export controls (i.e., commodity, software, code, technical information,
    technical materials, technical data, technical know-how, technical materials, technical
    processes, blueprint, design plan, prototype, proprietary information, industrial design or
    production, dual use, encrypted data, high performance computing, etc.)?
    • If yes
      • Contact Susan McDowell (mcdowes2@MiamiOH.edu)
  • If no hits in Steps 1, 2, 3, or 4, if you will not be carrying a Miami-issued laptop and/or smart
    device, and if no research that may be governed by export controls will be shared with a non-
    US person either at an international or domestic location
    • Proceed with international travel and/or collaboration (domestic or international)

If you have any questions or concerns, or would like the Office of Research and Innovation to conduct
the steps for you, please, contact Susan McDowell (mcdowes2@MiamiOH.edu)

 

Training

The online course (CITI Program) is composed of modules about research ethics, policies, regulations, and safety. Each module is completed by taking a quiz.

Initial Training

There are three basic modules for Export Compliance (EC): an Introduction and EC for Researchers Parts I and II. There are an additional ten modules that are specialized and may be relevant to your activities and required for you to complete by the export compliance coordinator, e.g. EC and Biosafety.

Refresher Training

Three years after initial training and every three years henceforth if still engaged in activities that might be impacted by EC regulations, you will be required to complete Refresher Modules (the number of modules depends on how recently you completed the original training and how the regulations and your activities have changed).

Susan McDowell
Export Control

Dr. Susan McDowell

Roudebush Hall, 102
Oxford, OH 45056
513-529-3603