Policies & Instructions
The U.S. Government controls the export of sensitive equipment, software, and technology in order to promote several of its objectives and interests, including:
- Restricting the export of goods and technologies that could contribute to the military potential of U.S. adversaries;
- Advancing U.S. foreign policy and economic goals; and
- Preventing the proliferation of weapons of mass destruction and terrorism.
UNH intends to comply fully and completely with all U.S. export control laws and regulations, including those implemented by the U.S. Department of Commerce through its Export Administration Regulations (EAR) and the U.S. Department of State through its International Traffic in Arms Regulations (ITAR) as well as those embargo regulations imposed by the U.S. Treasury Department through its Office of Foreign Assets Control (OFAC).
What is an export?
Under these regulations, an export can include:
- Sending or taking an export controlled item, material, or technical information out of the U.S.;
- Transferring export controlled technical information in the U.S. to a foreign person or entity (or to a U.S. person you know to be acting on behalf of a foreign person or entity) from a country for which a control exists; or
- Performing defense services, in the U.S. or abroad, for the benefit of a foreign person or entity from a country for which a control exists.
Why do export controls matter to UNH?
While the most common endeavors undertaken by an institution of higher learning (i.e., education and research) are ordinarily exempt from export control regulations, certain activities carried out in support of these objectives should be considered export compliance red flags:
- Traveling abroad with scientific equipment, or confidential, unpublished, or proprietary information or data;
- Traveling with a laptop computer, certain cell phones and other personal equipment;
- Use of third-party export controlled technology or information, especially if it is subject to a confidentiality agreement;
- Sponsored research that includes contractual restrictions on publication and dissemination, or access to, or participation by, foreign nationals;
- International financial transactions and international shipments;
- International collaborations & presentations; and
- International field work.
Where can you get assistance?
Violation of export control regulations is serious (and expensive) and can result in criminal and civil penalties against you, as an individual, as well as against UNH. Staff within the UNH Office of Contracts and Export Controls (CEC) and Research Integrity Services (RIS) are responsible for developing and implementing export compliance measures for all UNH activities and are available to assist you in complying with these regulations.
Contracts & Export Controls
Research Integrity Services