I. Scope:
This policy applies to all employees and students of the university, and to all persons holding any position affiliated with the university, including but not limited to Affiliate Faculty Members, and to all university contractors and employees of contractors (“University Community Members”).
II. Policy Statement:
United States export controls are Federal laws and regulations intended to protect U.S. economic and national security interests and to support U.S. foreign policy, which place restrictions on the provision of certain items, software, technology and services to foreign destinations and to Foreign Persons in the United States (“Export Controls”). Economic sanctions are Federal laws and regulations that implement U.S. foreign policy initiatives by restricting the types of services and transactions U.S. persons (and organizations) are permitted to provide to or enter into with Comprehensively Sanctioned or Embargoed Countries or Regions, designated organizations or individuals (“Sanctions”). In this Policy, Export Controls and Sanctions are collectively referred to as “Export and Sanctions Laws.”
It is the policy of the university to comply with all applicable Export and Sanctions Laws. All University Community Members must comply with the Export and Sanctions Laws. ORIA must be notified and any required licenses or approvals must be in place before:
(1) an Export or Deemed Export of Controlled Technology or Technical Data or provision of a Controlled Service is made, or a Controlled Item or Software is Exported; or
(2) providing services or entering into transactions with Comprehensively Sanctioned or Embargoed Countries or Regions, designated organizations or individuals.
University Community Members may contact the Office of Research Integrity and Assurance (“ORIA”) for information on the Export and Sanctions Laws.
III. Definitions:
Comprehensively Sanctioned or Embargoed Countries or Regions: Countries or regions designated by the Office of Foreign Assets Control as having comprehensive economic and trade sanctions imposed by the United States.
Controlled Technology or Technical Data, Controlled Service, Controlled Item or Software: For purposes of this policy, these terms include items, services, software, or technology/technical data identified on the Commerce Control List (15 C.F.R Part 774) in the General Prohibitions (15 C.F.R. Part 736), or the U.S. Munitions List (22 C.F.R. Part 121).
Deemed Export: Release or transmission of information subject to export control to any Foreign Person in the United States, including students and researchers. Such a release of information is considered to be an export to the home country of the foreign person.
Export: Any oral, written, electronic or visual disclosure, shipment, transfer or transmission of goods, technology, equipment, services, software, data or information out of the United States, or to a Foreign Person within the United States. Examples include the actual shipment of goods and the transfer of written documents or information via email, phone, internet, and verbal conversations.
Foreign Person: Persons who are not:
- U.S. citizens,
- U.S. permanent residents, or
- Persons who have been granted asylum in the United States, or any other protected individual as defined by 8 U.S.C. 1324b(a)(3)
Foreign person can also refer to any corporation, business association, partnership, trust, society or any other entity or group that is not incorporated in the United States or organized to do business in the U.S., as well as international organizations, foreign governments and any agency or subdivision of a foreign government (e.g., diplomatic mission)
IV. Responsibilities:
Each University Community Member is responsible for complying with and ensuring their activities conform to the Export and Sanctions Laws and Mason’s Export Control and Sanctions policies and procedures. ORIA will obtain any required government licenses or approvals before entering into any Export, Deemed Export, provision of service or transaction with a Comprehensively Sanctioned or Embargoed Country or Region, designated organization or individual. When questions arise individuals should contact ORIA for assistance.
V. Compliance:
Failure to comply with Export and Sanctions Laws may result in substantial civil and criminal fines and penalties to the university and the individual(s) involved; administrative sanctions such as loss of federal funding or Export privileges; and imprisonment for individuals involved. Failing to abide by the export control and sanctions policies and procedures adopted by the university can result in disciplinary action up to, and including, termination and expulsion. The university’s export control and sanctions procedures can be found in the Export Control Manual.
Any University Community Member who suspects or becomes aware of a potential or actual violation of Export and Sanctions Laws at the university, is required to report their suspicions to ORIA at [email protected]. The university protects individuals who make good faith reports of violations.
VI. Timetable for Review:
This policy, and any related procedures, shall be reviewed every three years or more frequently as needed.
VII. Amendments: Amendments will be approved by the Senior Vice President and Chief Operating Officer and the Provost and Executive Vice President.
VIII. Dates:
Approved: 6/28/2016
Revision Approved: 5/19/2021
Revision Approved 7/21/2026