Scope

The Export Control Compliance Manual (“Manual”) and the information on this web site govern and apply to all personnel, including faculty, staff, visiting scholars, postdoctoral fellows, graduate and undergraduate students, volunteers, and all other persons retained by or working at the University, wherever located (“WVU Personnel”), and to the activities of those persons. The Manual and this web site provide important direction to WVU Personnel to ensure that all of their activities comply with export control laws and regulations.

Export control laws and regulations cover a broad range of WVU activities, however, not all of those activities are addressed here. For further direction, please consult the Manual and/or contact the ECO directly.

The first step to compliance is determining whether a planned activity raises export control issues. Some of those activities may include:  

  • Performing or planning to perform research involving export controlled subject matter, equipment, or materials;

  • Hiring or planning the hiring of a non-immigrant employee, as defined in the Procedures;

  • Traveling internationally for University-related business;

  • Traveling for any reason to an embargoed country with University-owned equipment (including laptop computers, smart phones, tablets, etc.);

  • Accessing University e-mail, computer networks, or files while abroad;

  • Shipping technology, equipment, samples, or software outside of the U.S.;

  • Exporting or receiving export controlled technology, equipment,  software, etc. from another party;

  • Inviting or hosting visitors to the University who are non-U.S. persons;

  • Engaging in business transactions or legal agreements with foreign entities; or

  • Purchasing items from foreign entities or entities in foreign countries.


Certain characteristics of an activity may also be important to the export control determination. Red flags to look for include:

  • Bans or restrictions on publication or public disclosure of research results;

  • Indications that controlled technology and information will be supplied by the sponsor (check for references to export regulations in contracts or RFPs and request specifics from sponsor);

  • Involves encryption source or object code;

  • Results of research could be used for military purposes, including weapons of mass destruction or effect (WMD);

  • Restrictions in contracts or RFPs on the participation of non-U.S. persons;

  • Export of goods is likely; or

  • Sponsor is a foreign entity.