U.S. export control laws and regulations control the export, reexport and deemed export of certain commodities, software, technology/technical data, and services to foreign countries, foreign persons and foreign entities. The U.S. Government also administers and enforces embargoes and sanctions, as well as prohibiting participation in unapproved boycotts and bribery of foreign officials by U.S. persons.
While institutions of higher learning do not generally manufacture goods or provide services intended for export or transfer to a foreign person/entity, institutions like WVU do work extensively with technology/technical data, advanced instrumentation and equipment, software, and materials subject to export control restrictions. WVU also employs, collaborates with, does research for, or otherwise associates with many foreign persons and entities. Although there are certain specific export control exceptions that apply to institutions of higher learning, it is essential that WVU has a strong export compliance program to ensure compliance with these complex laws and regulations.
The WVU Export Control Compliance Program applies to the activities of all WVU personnel, including faculty, staff, visiting scholars, post-doctoral fellows, graduate and undergraduate students, volunteers and all other persons retained by, under contract or in partnership with WVU.
Examples of activities potentially requiring export control review include, but are not limited to the following.
- Exporting, transferring, or receiving export controlled technology, equipment or software from another party, within or outside the U.S.
- Performing or planning to perform research involving export controlled subject matter or equipment.
- Participating in research for which the sponsor restricts publication or participation by foreign persons.Hiring or planning to hire a foreign person.
- Traveling internationally to conduct University business or, for any reason, to an embargoed country with University owned equipment, software or technology.
- Accessing or having access to University e-mail, computer networks or files while outside the U.S.
- Inviting or hosting foreign person visitors to the University
- Engaging in business activity or legal agreements with foreign entities.
- Purchasing items from entities in foreign countries. Receiving boycott requests or requests in violation of the Foreign Corrupt Practices Act (FCPA).