The University of California is an internationally renowned, academic research institution, attracting a student body, staff, and faculty from around the world. Exchange of information with foreign colleagues occurs both on and off campus and it would be contrary to policy, as well as administratively impossible, to attempt to place any restrictions on the conduct of research and the dissemination of findings based upon citizenship status or nationality. University policy is that classrooms, libraries, laboratories, and specialized research facilities are open, without regard to citizenship, residency status, or visa category. To advance science, we must preserve the ability to communicate and disseminate the results of fundamental research among visiting scientists, scholars, students, and postdoctoral researchers, without the necessity of inquiry or concern for citizenship or residency status. To divide our community or limit access to our research programs, libraries, or facilities is both unworkable and unproductive.

At the same time, the University must comply with federal regulations, including those promulgated under the Export Administration Regulations (“EAR”) and the International Traffic in Arms Regulations (“ITAR”). These regulations are crafted in such a manner that publicly available, fundamental research results are excluded from the regulatory requirements for approvals or licenses. Specifically, publicly available information, technology and software as described in 15 CFR § 734.3(b)(3); § 734.7;  § 734.8; and § 734.10, are not subject to the EAR. Similarly, technical data in the public domain as defined in 22 CFR § 120.33 and set out in § 120.34 are exempt from the ITAR. In addition to general exclusions for information disseminated in an education environment, or which is publicly available or will be published, it is particularly important to note the exemption for fundamental research. Both the EAR and ITAR define fundamental research in a similar manner; it is "basic and applied research in science and engineering where the resulting information is ordinarily published and shared broadly within the scientific community, as distinguished from research the results of which are restricted for proprietary reasons or specific U.S. Government access and dissemination controls."

The right to publish and disseminate the results of university research is a keystone principle of the University of California. Fortunately, both EAR and ITAR recognize and protect the open, academic environment in the above-cited sections. Accordingly, no restrictions on foreign nationals' access to or participation in the design, fabrication, or scientific results generated in university-conducted fundamental research is required, so long as there is open access to the technical data or technology, and the results are shared broadly within the community. However, in cases where the University is fabricating an Item for shipment outside the U.S., once the design is finalized and scientific equipment fabricated, the University of California will secure any required export licenses prior to shipment. In this manner, the University can maintain an open academic environment, but also comply with the export regulations.

University of California, Riverside - Commitment to Export Control Compliance

University of California, Riverside - Export Compliance Program Plan (ECP)

University of California - Policy on Export Control

What are export controls?

U.S. export controls are federal laws that govern the conditions under which certain information, technology, technical data, materials, commodities, and equipment (“Items”) can be exported to a foreign person, entity, or country, or to a foreign national within the United States. The primary goal of export controls is to protect U.S. national security and promote U.S. foreign policy objectives.

U.S. export controls are administered by three key federal agencies. Click on each set of regulations to learn more.

Additional agencies within the U.S. Government that have a hand in export controls include:

• U.S. Customs & Border Protection (CBP)
• U.S. Census Bureau, Foreign Trade Regulations (FTR)
• U.S. Department of Agriculture (USDA)
• U.S. Department of Energy (DOE), National Nuclear Security Administration (NNSA)
• U.S. Nuclear Regulatory Commission (NRC)
• U.S. Department of the Interior, U.S. Fish & Wildlife Service
• U.S. Environmental Protection Agency (EPA)

What is an ‘export’?

In general terms, an export is defined to mean the shipment or transmission of Items out of the United States, or the release of technology, technical data or source code to a foreign person in the United States (i.e., deemed export). Examples of exports that a university may encounter include:

• transfers (release) of information or technology, including technical data, to persons and entities outside the United States.
• shipment of Items such as materials and equipment from the United States to a foreign country.
• verbal, written, electronic, or visual disclosures of controlled scientific and technical information or technology related to export-controlled Items to foreign persons, even when it occurs within the United States ("deemed exports"); and
• transactions with sanctioned or embargoed countries or restricted or debarred individuals or entities.

What is a ’deemed export’ and how do they take place?

A deemed export is the release or transfer of technology, technical data or source code that is subject to U.S. export controls to a foreign person (national) while in the United States. Such release or transfer is "deemed" to be an export to the foreign person's most recent country of citizenship or permanent residency. The following are hypothetical examples of deemed exports under the ITAR and EAR, which may require an export license approval.  

• Posting ITAR-controlled information to an open discussion board website
• Discussing ongoing ITAR-controlled research with a foreign person (e.g., foreign collaborators or colleagues) 
• Tours of facilities or laboratories wherein detailed production documents for ITAR-controlled research is observed
• Visual inspection of documents that result in EAR-controlled technology or source code being released
• The release of EAR-controlled technology or source code to a foreign person while conducting collaborative research 

What is ‘technology’ or ‘technical data’?

These terms refer to technical information beyond general and basic marketing materials of an export-controlled Item. These terms do not refer to the export-controlled Item itself, or to the type of information contained in publicly available user manuals. Rather, the terms "technology" and "technical data" mean specific information necessary for the development, production, or use of a commodity, and usually takes the form of blueprints, drawings, photographs, plans, diagrams, models, formulae, tables, engineering specifications, and documentation.

What is an ‘export license’ and when do I need one?

An export license is a government document that authorizes or grants permission to conduct a specific activity or transaction. Activities can include, but are not limited to, hand-carrying or shipping an Item, sending information or data about an Item electronically, or sharing information about an Item through a phone, virtual, or in-person conversation.

Your activity or transaction may require an export license if i) the destination or recipients are restricted; ii) the export classification of the Item (including technology or technical data) indicate a licensing requirement based on its reasons for control; or iii) if the planned end uses of the Item are restricted, such as for use in military applications or in support of a military end-user. It is important to note that end-user and or end-use restrictions may necessitate a licensing requirement even if the Item and destination do not.

The method used in transporting an Item outside the United States does not matter in determining export license requirements. Accordingly, for all export-controlled Items, an export license or license exception may be required prior to the export or deemed export taking place. To determine if your activity or transaction requires an export license or eligible for a license exception or exclusion, please contact the Export Control Office.

What can happen if we do not comply with U.S. export controls?

Individuals and institutions who violate federal laws and regulations that govern the conduct of export-controlled activities are subject to penalties, including fines, jail terms, suspensions, denial of export or research privileges, and debarment from government contracting.

Penalties for violating export controls include:

• ITAR Criminal (22 CFR § 127.3): $1 million per violation, 20 years in jail, or both
• ITAR Civil (22 CFR § 127.10): the greater of $1,200,000 or the amount that is twice the value of the transaction that is the basis of the violation
• EAR Criminal (15 CFR § 764.3(b)): $1 million per violation, 20 years in jail, or both
• EAR Civil (15 CFR § 764.3(a)(1)): $328,121, per violation or twice the value of the transaction, whichever is greater
• OFAC (31 CFR 501): One-Half of Transaction Value or applicable statutory maximum per violation, whichever is greater (penalties vary based on statute and country specific sanctions programs)
• PLUS, possible debarment or denial of export privileges/denial of right of foreign parties to receive U.S. goods and technology.
• The U.S. Government can also suspend the right to contract with U.S. Government agencies

Voluntary self-disclosures, if made appropriately, can mitigate the seriousness of the penalty. Contact the Export Control Office immediately if you think you have made a mistake and violated applicable export controls.

For additional information and resources on export controls, please visit the 'Training Resources' block of this website.

Related Resources

Export Control and University Research | BIS

Export control laws and regulations | UCOP | ECAS

Frequently Asked Questions about Export Control Compliance | UCOP | ECAS

Openness of the University Research Environment

The University of California’s strategy for compliance with applicable U.S. export controls is based upon maintaining an open, fundamental research environment, by observing the freedom to publish and disseminate research results and practicing nondiscrimination and open access to university classrooms, libraries, laboratories, and specialized research facilities, without regard to citizenship. To maintain the fundamental research environment, such that scientific data and results qualify as being in the “public domain” under the ITAR and are not subject to the EAR under the provisions related to publicly available technology; published information and software; information resulting from fundamental research; and educational information; the university may not accept such restrictions in a research award, and in addition, no university employee can consent (in a written or verbal side agreement or arrangement) or otherwise engage in behavior that restricts publication or the participation of foreign persons.

Procedures and Guidance Documents

Compliance Alert - New Advanced Computing, Semiconductor and Supercomputer Controls

Compliance Alert - Federal laws may regulate research/telework from certain countries

Compliance Alert - Federal laws may regulate whether you can provide online classes to students outside the United States

Compliance Alert - Russia, Belarus and Specific Regions of Ukraine

Export Control Documents and Procedures

Fundamental Research

The National Security Decision Directive 189 (NSDDs 1985) defines fundamental research as “basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community, as distinguished by proprietary research and from industrial development, design, productions, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons.”

Under the ITAR, fundamental research is defined as basic and applied research in science and engineering at accredited institutions of higher learning in the United States where the resulting information is ordinarily published and shared broadly within the scientific community, as distinguished from research for which the results are restricted for proprietary reasons, or specific U.S. government access and dissemination controls.

The EAR defines fundamental research as research in science, engineering, or mathematics, the results of which ordinarily are published and shared broadly within the research community and for which there researchers have not accepted restrictions for proprietary or national security reasons.

When conducting fundamental research, a fundamental research exclusion (“FRE”) is available if the resulting information is not subject to the ITAR or EAR meeting the following criteria:

• The research activity cannot constitute industrial development, designed, or utilization as indicated by any type of proprietary restriction imposed by the sponsor.

• The agreement and research activity may not include any type of contractual or national security restrictions, such as foreign person prohibitions or prepublication approval of the research results by the sponsor.

Please take note that even in the conduct of fundamental research, an export license or control plan may be required if the project involves any of the following:

• an NDA covering the exchange of export-controlled information;
• access to export-controlled items, including technology, software, biological items and select agents;
• a non-research function (e.g., a service agreement) where there is access to export-controlled items, technology, or software; or
• access to ITAR-controlled equipment and its associated technical data.

Researchers are encouraged to publish research results, including technology and software, in a timely manner (e.g., early, and often) through one of the means that qualifies as "publicly available" or "in the public domain." Publicly available technology and software is that which is:

• Already published or will be published in journals, books, open websites, or other media available to a community of persons interested in the subject.
• Published through release at open conferences and meetings.
• Arises during or results from fundamental research where the resulting information is ordinarily published and shared broadly within the scientific community and where no contractual controls have been accepted.
• Educational information released by instruction in catalog courses and associated teaching laboratories of the university.
• Included in certain patent applications.

For additional information on exclusions pertaining to fundamental research, controlled items, and a list of steps for researchers to maintain the fundamental research environment, please visit the Export Control Documents and Procedures webpage or contact the Export Control Office for guidance. 

For additional information and resources on export controls, please visit the 'Training Resources' block of this website

Related Resources

Citizenship and nondiscrimination | UCOP | RPAC

Ownership and Dissemination of Research Results | UCOP | RPAC

UC’s Export Compliance Plan | UCOP | ECAS

Steps for Researchers to follow to adhere to UC's Export Compliance Plan | UCOP | ECAS

On-Campus Research with Foreign Nationals | UCOP | ECAS

Working with Restricted Entities | UCOP | ECAS

Identify and Safeguard Controlled Information | UCOP | ECAS

Activities performed by Procurement Services may involve controlled products, materials, equipment, software, and technology (“items”) or services and could be subject to export licensing requirements.  To ensure compliance with these requirements, UCR requires that all vendors, suppliers, persons, or subcontractors identify all known export control classifications and other related restrictions for the items or services they provide to UCR. Because UCR will rely upon this information in complying with its export compliance obligations, UCR trusts that all vendors, suppliers, persons, or subcontractors will provide the most accurate and up-to-date information.

Procedures and Guidance Documents

Compliance Alert - New Advanced Computing, Semiconductor and Supercomputer Controls

Compliance Alert - Russia, Belarus and Specific Regions of Ukraine

Export Control Documents and Procedures

Infographic

Requests for Export Control Classification

Prior to order placement, all vendors, suppliers, persons, or subcontractors must complete an Export Control Classification Request ("ECCR") form for all items or services provided to UCR, including any associated technology, software or sensitive sub-components (e.g., those potentially subject to restrictions) contained therein. 

ECCR's must be fully completed and duly signed before being returned and accepted by UCR Procurement Services. Completed ECCR's will undergo an export control licensing review by UCR's Export Control Office to ensure there are no export control restrictions or controlled items that may prevent or delay order placement. 

Examples of items or services that may contain export control restrictions or controlled items include (not inclusive):

• Process Design Kits (i.e., "known how," intellectual property, designs, manuals, blue prints for sensitive items)
• Satellite components or accessories
• Night vision or infrared cameras
• Sonobuoys and submersible vessels
• Navigation, defense navigation or avionics equipment
• Military communications systems/high frequency radio apparatus
• Military electronics/ruggedized components
• Radar equipment
• Biological agents
• Gas monitoring/filtration devices
• Optical lens or photonics instruments or components
• Sensors, infrared light detectors, thermal imaging cameras, and focal plane arrays
• Oscilloscopes or Spectrometers
• Nuclear/radioactive equipment/devices
• Lasers
• Semiconductor equipment
• Fiber optic cables and filaments
• Unmanned Aerial Vehicles (UAVs)
• Gravimeters
• Integrated Circuits (ICs)

For additional information and resources on export controls, please visit the 'Training Resources' block of this website

Related Resources

Procurement Services | Policies & Procedures | UCR 

Procurement Services | Forms & Resources | UCR

Working with Restricted Entities | UCOP | ECAS

FCPA Information and Resources | UCOP | ECAS

In general, collaborations between university personnel and scholars at foreign institutions or organizations do not require export license approval unless they involve controlled items or other regulated activities, a restricted party, or a sanctioned country or other country of concern. Therefore, before engaging in international collaborations, the university must verify whether prior export license approval is required.    

Procedures and Guidance Documents

Compliance Alert - New Advanced Computing, Semiconductor and Supercomputer Controls

Compliance Alert - Federal laws may regulate research/telework from certain countries

Compliance Alert - Federal laws may regulate whether you can provide online classes to students located outside the Unites States

Compliance Alert - Russia, Belarus and Specific Regions of Ukraine

Faculty One Page On Global Engagement

Export Control Documents and Procedures 

Activities Involving Sanctioned Countries or Restricted Parties

Due to the frequency of U.S. export control regulatory changes, Restricted Party Screening should be performed at the outset of any international collaboration, including financial transactions and visiting scholars or researchers, to ensure that the collaborating entity, individual or country does not appear on any U.S. Government restricted party list subject to licensing requirements. 

• Sanctioned countries and countries of concern include China, Cuba, Iran, North Korea, Syria, Russia, Belarus, Ukraine. For an updated list of sanctions programs and country information, visit: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information

Researchers should contact the Export Control Office as soon as possible to ascertain whether a license would be required for any of the following activities involving a restricted party, a sanctioned country or other country of concern: 

• import or export of items (i.e., research samples, items used in or developed during research, end items, research material and equipment etc.)
• collaboration with individuals residing in or visiting from a sanctioned country or other country of concern
• research, training, or field work (including telework and consulting) 
• procuring of items 
• international travel (including to attend or present at a conference or webinar)
• transfer of funds

Note: in the event an export license is required from the U.S. Government, an approved license must be obtained prior to proceeding with any international collaboration. While there is no guarantee or exact timetable for issuing a license, the license review process can take 4 to 6 months. License applications covering more complex transactions can take up to a year or longer for the U.S. Government to process. Researchers are encouraged to contact the Export Control Office as soon as possible for the most recent guidance to avoid penalties and delays to your research.

For additional information and resources on export controls, please visit the 'Training Resources' block of this website

Related Resources

APM – 430, Visiting Scholars and Other Visitors | UCOP | RPAC

International Collaborations and Economic and Trade Sanctions OFAC | UCOP | ECAS

Working with Restricted Entities | UCOP | ECAS

Foreign Influence | UCOP | ECAS

Hosting Foreign Visitors | UCOP | ECAS

In general, export control requirements for international travel can vary depending on the country of destination, purpose and items carried. Prior to travel, individuals are advised to review all relevant travel restrictions for the country of destination and to conduct Restricted Party Screening to determine if the individuals or entities with whom you desire to do business with are on any U.S. Government restricted list.

Procedures and Guidance Documents

Compliance Alert - Russia, Belarus and Specific Regions of Ukraine

Export Control Documents and Procedures

Infographic 

Travel to countries under comprehensive sanctions (Cuba, Iran, North Korea, and Syria)

Traveling to a country under comprehensive U.S. sanction, and interactions with organizations or individuals in them, are highly regulated. Prior to travel, authorization from the U.S. Government in the form of a license may be required for any of the following activities:

• Financial transactions
• Providing a service (of any kind) 
• Conference attendance or presentations
• Conducting research 
• Education or outreach
• Hand carrying laptops, equipment, material or information as part of your travel 

Note: Travel and interactions with organizations or individuals located in Ukraine may require special approval. Please contact the Export Control Office for additional information. 

Travelers should contact the Export Control Office to assist with determining if your particular travel plans and circumstance requires license approval.     

Travel to countries deemed a national security risk by the U.S. (Belarus, Russia, China, Venezuela, and Burma)

If your travel includes a country where the U.S. Government has heightened concerns that civilian goods or services may be diverted to a military end use or user, additional requirements may apply. University-owned items or information you bring may require an Electronic Export Information (EEI) filing prior to leaving the U.S.

Examples of items that may require an EEI filing include:

• Laptop or smartphone
• Equipment or instruments
• Research samples or data
• Proprietary or export controlled information

Travelers should contact the Export Control Office prior to travel to assist with determining any additional requirements that may apply to their particular plans and circumstance. 

Sanctions Programs and Country Information (OFAC)     Travel Advisories (U.S State Dept.)

Hand carrying computers, research materials, and samples or equipment as Tool of the Trade

When you travel abroad, everything you take with you is an export including hand carried equipment, research materials, and unpublished or proprietary information or data. Before taking any university-owned item abroad, individuals are advised to complete a Request to Hand Carry form and contact the Export Control Office for assistance with:

• Determining your items export control classification.
• Determining whether an export license is required.
• Securing an export license when needed.

Request to Hand Carry       ITS INT'L TRAVEL LOANER PROGRAM

Note: if you are traveling with an electronic device such as a laptop, tablet, or smartphone, you are taking a controlled device with you. There may be limitations for taking these items into certain countries. 

Note: while traveling, university-owned items should be free from customized software or stored or accessible controlled technology. Individuals should consult with the Export Control Office and Information Technology department to verify if there are any restrictions with encryption technology or software, or other export-controlled items on a university-owned item that will be used for business purposes. When time is of the essence, individuals should consider utilizing a device that is free of encryption technology or software. 

Note: when traveling, if you access your cloud-account, you have exported the information into the country where you are at the time. If any of that information is export-controlled, a violation may have occurred. This holds true even if you are U.S. citizen and you uploaded the information while in the U.S. and you are accessing your account from a UCR or personally owned device. You should not access any information from a cloud account during international travel unless you are 100 percent certain the information is not export-controlled or considered proprietary.

Please contact the Export Control Office to review if there is a license exception/exemption available for your particular travel plans and circumstances.

For additional information and resources on export controls, please visit the 'Training Resources' block of this website

Related Resources

Travel Policy, Regulations, and Procedures | UCR | BFS 

Travel Insurance and Planning | UCR | Risk Management

Traveling with Electronic Devices IT Guidance | UCOP | SIS

UC Travel Insurance | UCOP | Risk Services 

International Travel | UCOP | ECAS

Faculty One Page on Global Engagement | UCOP | ECAS

To help ensure that UCR faculty, staff, and students do not experience customs delays, seizure of goods, or inadvertently violate U.S. export controls; the following information is provided as a general overview of the basic requirements for international shipping and the hand carrying of items abroad. 

Procedures and Guidance Documents

Compliance Alert - New Advanced Computing, Semiconductor and Supercomputer Controls

Compliance Alert - Russia, Belarus and Specific Regions of Ukraine

Export Control Documents and Procedures 

Infographic

General Information

The shipment or hand carrying of scientific equipment, materials, or other export-controlled items from the U.S. to a foreign destination, could require an export license depending on the items export classification, country of destination, end-user and end-use. An export license may be required even when the item is used in or results from fundamental research.

Before making an international shipment or hand carrying items abroad, exporters must know the answers to the following questions:

Red Flag Indicators in Export Transactions

The following "red flags" are adapted from a checklist provided by the U.S. Department of Commerce, Bureau of Industry and Security ("BIS"). While not inclusive, this list is intended to illustrate that types of transactions that may have a heightened level of risk of violating export control regulations.  

• The recipient or its address is similar to one of the parties found on a Restricted Party Screening result.
• The recipient or purchasing agent is reluctant to offer information about the end-use of the item.
• The requested materials or product's capabilities do not fit the recipient's line of business or expertise.
• The requested materials are incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry.
• The recipient is willing to pay cash for the material.
• The recipient has little or no academic, scientific, or research background.
• The recipient is unfamiliar with the material's or product's performance characteristics but still wants the product.
• Routine installation, training, or maintenance services are declined by the recipient.
• Delivery dates are vague, or deliveries are planned for out of the way destinations. 
• A freight forwarding firm is listed as the product's final destination.
• The shipping route is abnormal for the product and destination.
• Packaging is inconsistent with the stated method of shipment or destination.
• When questioned, the recipient is evasive and especially unclear about whether the requested material or product is for domestic use, for export, or for reexport.

If any of the listed red flags or other suspicious circumstances are present in your transaction, as the exporter, you have the duty to exercise due diligence to ensure there is an appropriate end-use, end-user, or ultimate country of destination. If you continue to have reason for concern after your inquiry, you are advised to refrain from the transaction and escalate all relevant information concerning the transaction to the Export Control Office for further review and assistance. 

Note: transactions containing red flags may require specific documentary evidence certified by the recipient concerning the transaction to ensure there is an appropriate end-use, end-user, or ultimate country of destination. 

Export License Review for International Shipments

Before making an international shipment, UCR faculty, staff, and students are advised to complete a Request to Ship form and contact the Export Control Office for assistance in:

• Determining your items export control classification.
• Determining whether an export license is required.
• Securing an export license when needed; and
• Advise on specific documentation requirements for export shipments.   

Request to Ship Form          REQUEST TO HAND CARRY FORM    

Biological Materials, Hazardous or Dangerous Goods, Dry Ice Shipments

Federal, state and international law strictly regulate shipping, transport, and import of biological materials and other hazardous or dangerous goods. Individuals must obtain all necessary permits prior to the importation of any biological materials, hazardous or dangerous goods.

Individuals are advised to contact EH&S Biosafety concerning packaging, marking and permit requirements for the import or export of biological materials, hazardous or dangerous goods, and shipments involving dry ice.  

UCR Environmental Health & Safety

Logistics / Transportation

The University of California has Systemwide Agreements for Customs Brokerage & International Freight Forwarding Services with American Cargo Services (ACS) to assist with clearing import and export shipment through U.S. Customs and provide freight-forwarding services. Each department is responsible for determining the best method and logistics company used in transporting their items, freight, and cargo to the desired end-use location, which may not always be ACS. Departments requiring assistance in selecting carriers for outbound shipments may contact ACS or UCR Receiving Services.

 American Cargo Services (ACS)           UCR Receiving Services   

Note: exporters are advised to contact their international collaborators to inquire regarding the import requirements for the destination country. Imports may be stopped by customs officials in the importing country if the proper import licenses are not included in the paperwork. Import requirements vary greatly by country.

For additional information and resources on export controls, please visit the 'Training Resources' block of this website

Related Resources

Environmental Health & Safety | UCR

International Shipping |UCOP | ECAS

Working with Restricted Entities | UCOP | ECAS

Faculty One Page on Global Engagement | UCOP | ECAS

As promulgated under UC's Export Control Policy, compliance with export controls is a shared responsibility. As the exporter, we have a responsibility to know who we are conducting business with, as engagements with international parties appearing on one of several U.G. Government debarred, denied or sanctioned lists, collectively referred to as "restricted parties," carry specific regulatory requirements and may pose significant compliance risks to UCR, its faculty, and staff.    

To minimize such risks, as part of UCR's Export Compliance Program Plan (ECP), Restricted Party Screening must be performed for international activities and transactions to assess whether the parties involved are a restricted party; and determine, with the support of the Export Control Office, if the proposed activity or transaction is authorized, or if approval is required from the relevant government agency.

Procedures and Guidance Documents

Compliance Alert - Federal laws may regulate research/telework from certain countries

Compliance Alert - Federal laws may regulate whether you can provide online classes to students outside the United States

Compliance Alert - Russia, Belarus and Specific Regions of Ukraine

Export Control Documents and Procedures

Infographic

What is Restricted Party Screening, and why is it important?

Restricted Party Screening (RPS) is a process used to identify whether an individual, organization or entity (e.g., business, corporation, institution etc.,) involved in the activity or transaction are a restricted party found on a U.S. Government list. The importance of RPS is to ensure that exporters are not conducting business with a restricted party—be it an individual, organization or entity.

Additionally, RPS can also be used to ensure that exporters are not engaging in international activities or transactions with parties located in a sanctioned or embargoed country  or country of concern (e.g., Cuba, Iran, North Korea, Syria, Russia, Belarus and Ukraine) without the proper authorization, such as an export license.  

What are the U.S. Government lists?

The U.S. Government maintains several different publicly available lists, and are updated on a nearly daily basis. These lists include but are not limited to:

• Denied Persons List - Individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order are prohibited.
• Entity List - Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The List specifies the license requirements and policies that apply to each listed party.
• Unverified List - End-users who the Bureau of Industry and Security has been unable to verify in prior transactions. The presence of a party on this list in a transaction is a "Red Flag" that should be resolved before proceeding with the transaction.
• Military End User (MEU) List - Parties whose presence in a transaction as a party to the transaction triggers a license requirements for any item subject to the EAR listed in Supplement No. 2 to Part 744.  
• Nonproliferation Sanctions - Parties that have been sanctioned under various statutes.
• Debarred List - Entities and individuals prohibited from participating directly or indirectly in the export of defense articles, including technical data and defense services.
• Specially Designated Nationals (SDN) List - Parties who may be prohibited from export transactions based on regulations administered by the Department of the Treasury’s Office of Foreign Assets Control (OFAC).
• Non-SDN Menu-Based Sanctions List (NS-MBS List) - Persons subject to certain non-blocking menu-based sanctions that have been imposed under statutory or other authorities, including certain sanctions described in Section 235 of the Countering America's Adversaries Through Sanctions Act (CAATSA). 
• Non-SDN Chinese Military-Industrial Complex Companies (CMIC) (NS-CCMC) - This publication by the Department of the Treasury's Office of Foreign Assets Control (OFAC) is designed as a reference tool that identifies persons subject to certain sanctions that have been imposed under statutory or other authorities, including certain sanctions. 
• Foreign Sanctions Evaders List - Foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions programs, as well as foreign persons who have facilitated deceptive transactions for or on behalf of persons subject to U.S. Sanctions. Transactions by U.S. persons or within the United States involving Foreign Sanctions Evaders are prohibited. 
• Sectoral Sanctions Identifications (SSI) List - Individuals operating in sectors of the Russian economy with whom U.S. persons are prohibited from transacting in, providing financing for, or dealing in debt with a maturity of longer than 90 days.

When is RPS needed and who should be screened?

RPS should take place at first contact, prior to the export, reexport, transfer or financial transaction taking place, and should be performed for all international activities. RPS should include every party involved in the transaction, including the end user, affiliated entity for international scholars and collaborators and any of the parties involved in throughout the transaction, including partner resources such as supercomputing centers.  

What tools and resources are used to perform RPS?

Within the UC System, the tool used to perform RPS is Descartes Visual Compliance. Visual Compliance is a web-based tool and is made available for use by all UC campuses. UCR faculty, staff and students involved in export activities or transactions can self-register for a Visual Compliance account using their UC email address.

Step-by-step instruction on how to self-register for a Visual Compliance account and perform an RPS can be found in the Restricted Party Screening, End-Use & End-User Check procedure under Export Control Documents and Procedures.

Self-Register           Returning User      uCR RPS Training video (NetID required)

For additional information on the Restricted Party Screening process, please visit the 'Training Resources' block of this website. 

To obtain additional information on Visual Compliance, U.S. Government restricted party lists and current sanctions or embargo programs, please contact the Export Control Office. 

Related UCOP Policies and Resources

University of California – Policy on Export Control | UCOP | RPAC

Working with Restricted Entities |UCOP | ECAS

Training is an important part of UCR’s Export Compliance Program Plan. UCR’s Export Control Office provides various trainings - from in-person to online - aimed at helping to better understand and navigate complex U.S. export control regulations and sanction laws. The goal of UCR’s Export Control Training Program is to educate and empower UCR faculty, staff and students to know when and how to ask for help to prevent non-compliant activities that may lead to potential violations.

Basic Education and Training

The following training videos are made available to all UCR faculty, staff and students via the Learning Management System (LMS):

In addition to export control basics, the University of California (UC) has developed a four part video series on the topic of Research Security Programs. The following video shorts aim to introduce UC researchers, administrators and others on four key elements of Research Security Program requirements: 

Training for Subject Matter Experts

UCR has partnered with the Collaborative Institutional Training Initiative ("CITI Program") to offer additional on-demand export compliance training content. CITI Program's on-demand 'Export Compliance' training course include: 

• Export Compliance for Researchers
• Export Compliance for Researcher Administrators 
• Export Compliance When Using Technology in Research 
• Export Compliance and Biosafety
• Export Compliance for Operational Departments
• Export Compliance for International Shipping
• Export Compliance and Purchasing
• Export Compliance and International and Foreign Waters
• Export Compliance and Collaborations
• Export Compliance and Distance Education 
• Export Compliance and United States Sanctions Programs

The above Export Compliance course are available to all UCR faculty, staff and students via CITI Program's Single Sign On (SSO) option. To get started, please make your selection below:   

Please contact the Export Control Office at exportcontrol@ucr.edu with any questions regarding your training needs.

Related Resources

Education and Training | UCOP | ECAS

Faculty One Page on Global Engagement | UCOP | ECAS

Frequently Asked Questions about Export Control Compliance | UCOP | ECAS

U.S. Government Training Videos and Materials

Export Controls and University Research | U.S. Department of Commerce | BIS

Complying with Export Regulations | U.S. Department of Commerce | International Trade Administration

Foreign Import Regulations | U.S. Department of Commerce | International Trade Administration

Harmonized System | HS Product Code | U.S. Department of Commerce 

A Guide to the Harmonized Tariff Schedule of the United States | U.S. International Trade Commission

How to Submit Your Electronic Export Information (EEI) | U.S. Department of Commerce | International Trade Administration

The Automated Export System (AES) | Legal Requirements for Filing AES | U.S. Department of Commerce | International Trade Administration

The Authorized Agent as an Option for Filing the EEI | U.S. Department of Commerce | International Trade Administration

ACE and Automated Systems | U.S. Customs and Border Protection 

AESDirect User Guide for filing Electronic Export Information | U.S. Census Bureau

Exporting Documentation | U.S. Department of Commerce | International Trade Administration 

It is the policy of the University of California to respond promptly to all reports of suspected violations of law and other non-compliance with the University of California - Policy on Export Control, and to take appropriate action to correct and prevent future violations. Accordingly, any unauthorized, suspected, or illegal export transactions that may lead to a possible violation of U.S. export controls, whenever discovered, must cease, and be reported immediately for review and investigation.

Procedures and Guidance Documents

Commitment to Export Compliance | UCR

Export Control Documents and Procedures

Reports of a suspected non-compliant activity can be made either in person or electronically (e.g., by telephone, email or online) without fear of retaliation. Sufficient information must be provided to allow the designated officials to pursue an appropriate course of action in the event of an actual or potential violation. All reports of potential violations are kept confidential in accordance with applicable laws. When reporting on a suspected non-compliant activity, individuals are encouraged to report all known facts and details as available.

Reports can be sent to:

Related Resources

Chief Compliance Office | UCR