Procedures

The following are the most common University activities that require review by the Export Control Office (“ECO”). The procedures that must be followed for each activity are outlined in detail below.


      Hiring of Non-immigrant Workers and Visiting Scholars: Visa Applications

      Before a WVU unit can hire or otherwise engage a non-immigrant worker or visiting scholar on any of the following visas, H-1B, J-1, or O-1, the Deemed Export Verification for Non-immigrant Visa must be completed and submitted to the ECO.

      The export control review includes the following:

      • A restricted party screening of the applicant;
      • A restricted party screening of the foreign affiliation of the applicant;
      • A list of all blocked persons from the country of citizenship of the applicant; and
      • A technical screening of the project or equipment, if any, to be assigned to the applicant if hired. 
      Please note that a current job description, list of current projects (funded and unfunded), and equipment assigned to the applicant are required for all visa renewals.

      Important information about timing:

      Please submit the completed WVU Deemed Export Verification for Non-Immigrant Visas Form to the ECO at least three months in advance if the hiring unit has any reason to believe that export controlled material may be involved in the projects or equipment to be assigned to the applicant if hired. A federal license may be needed before the non-immigrant worker can begin work and this could require extra time.

      Please direct questions related to the timing and submission of these forms to the ECO at exportcontrol@mail.wvu.edu.

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      International Travel

      An export control screening is required for WVU Personnel on international travel related to WVU business or travel to embargoed countries with WVU-owned equipment or access to WVU networks. WVU Personnel must register their travel no later than one month prior to departure.  If you are traveling to an embargoed or sanctioned country or if your travel may involve export controlled subject matter or equipment, contact the ECO at least three months in advance of travel in case a license is required.

      The Office of Global Affairs hosts the International Travel Registry.  WVU Personnel should use the registry to request an export control screening for any upcoming travel.

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      Accessing WVU E-mail while Traveling Abroad

      WVU Personnel accessing WVU e-mail when traveling abroad must comply with the current version of Best Practices to Maintain Security of Controlled Technology or Technical Data During International Travel. WVU Personnel will be asked to submit this signed document once per fiscal year to the ECO to affirm that the traveler has read and understood the content. This form is included in the WVU Abroad international travel registry from the Office of Global Affairs.

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      Export Control Screening of Externally Funded Research Grants and Contracts

      The ECO will work closely with the Office of Sponsored Programs (OSP) to screen for export control restrictions in externally funded research grants and contracts. An export control screening can be triggered by a variety of research scenarios, including a research sponsor’s insistence on having the right to restrict publications, review publications before approving them, or prohibit the involvement of non-U.S. persons in the work.

      The OSP has primary responsibility for identifying awarded grants and contracts that require export control screening. Upon making such a determination, the OSP will notify the principal investigator of the grant or contract in question that an export control screening is required. The OSP will forward a copy of the statement of work of the flagged grant or contract to the ECO and instruct the principal investigator to contact the ECO to facilitate an export control screening of the project. The OSP will not allow the affected grant or contract funding to proceed until: the ECO conducts the required screening; the principal investigator acknowledges the results of the screening in writing; and the principal investigator agrees in writing to abide by any written instructions or technology control plan (TCP) issued by the ECO.

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      Inviting International Visitors to WVU

      Please contact the ECO before inviting or accepting a visit from a non-U.S. person, who does not currently reside in the United States and who may engage in or discuss WVU-related research or academic activities or otherwise exchange such information. The WVU Personnel who is hosting the visit must notify the ECO in advance so the ECO can determine if the visitor is on a federal restricted party list, associated with a restricted entity, or if there are other export control concerns related to the visit. This information can be provided on the WVU International Visitor Form. Please contact the ECO directly if there are questions. Necessary information includes, but is not limited to:

      • The legal full name of the visitor(s);
      • Visitor’s employer/affiliation;
      • The purpose of the visit and what the visitor(s) will see/use during the visit;
      • The dates when the visitor(s) will be on the WVU campus; and
      • The name(s) of the WVU Personnel who is hosting the visitor(s); and
      • A copy of the passport or CV/resume of the visitor(s), if available.

      In addition to following all guidance provided by the ECO for a particular visit, WVU Personnel hosting the international visitor(s) should do the following, as applicable:

      • Escort the visitor at all times on the WVU campus;
      • Prior to the meeting/visit, inform all staff members who may be involved of the limitations regarding the release of controlled technical data to the foreign visitor;
      • Ensure that the conference room and other areas to be visited do not have any export control information readily visible to the visitor;
      • Review all information to be disclosed or disseminated during the visit to ensure that no information is export controlled;
      • Immediately report any incidents or suspected incidents as well as any improper information requests from the visitor; and
      • Ensure the visitor(s) only has access to publically available information.

      Please also see the Visiting Scholars Guidelines for more information on inviting a visitor to campus.

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      All WVU Personnel planning to engage in legal agreements and business transactions (including procurement card transactions) with foreign persons and entities must contact the ECO for assistance prior to negotiating those legal agreements or effecting the transaction.

      Upon receipt of the name(s) of the relevant foreign party(ies), the ECO  will conduct a restricted party screening and provide a written response, usually within two business days. This may take longer depending on the technology involved and the parties’ responsiveness. The response will either indicate that the screening revealed no matches and the proposed agreement or transaction may move forward as planned or identify any match revealed by the screening and explain the next steps that need to be taken to ensure compliance with export control laws.

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      Purchasing or Receiving Export Controlled Items

      While most of the products that are purchased or received by WVU Personnel are not export controlled, some items may fall under the control of the Department of State or the Department of Commerce. WVU Personnel planning purchases (including those with a procurement card) should consider whether the items to be procured may be subject to export controls. The ECO can assist in this determination if the company cannot provide the information.

      If the items to be purchased are subject to export controls, the WVU Personnel responsible for the purchase must notify the ECO via email prior to issuing the purchase request (purchase order, procurement card, etc.). Prior to receipt of the export controlled item, the  WVU Personnel responsible for the purchase shall work with the ECO to ensure that upon receipt it is properly marked with an appropriate notice and properly handled (e.g. stored in a secure area, etc.).

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