Category

Export Controls

An overview of export controls, confidentiality agreements, encryption code, shipping or carrying Stanford equipment outside the U.S., and a decision tree to determine if export controls apply to your activity.

2025 Federal Administration Transition Information & Resources - This will be updated as new information is available.

Dismiss

9 Topics

  • Export Controlled or Sanctioned Countries, Entities and Persons

    Alert: The US Department of the Treasury now requires export licenses for the export or import of ALL goods, services, or technology to or from the so-called Donetsk People's Republic or the Luhansk People's Republic of Ukraine, with the exception of certain agricultural commodities, medicine, and medical supplies. When considering whether or not a shipment, transfer, transmission, or disclosure

    July 8, 2024

  • Export Controls: H1-B Deemed Export Certification

    Introduction Requirements and workflow related to H1-B Export Certification. Employer Requirements The Department of Homeland Security's US Citizenship and Immigration Services (USCIS) now requires all employers to assess whether an export license must be obtained prior to hiring any H1-B employee, and to certify to those findings. This certification requirement implements laws presently set forth

    November 28, 2023

  • Export Controls: Confidentiality Agreements

    This is a guide to understanding Stanford policies, procedures, and resources for non-disclosure and confidentiality agreements. In the course of their work, Principal Investigators and other researchers may be asked to accept confidential or restricted information, materials, software code, or technology from a sponsor or third party. The sponsor or third party will require that the researcher sign a Non-Disclosure Agreement (NDA).

    March 26, 2025

  • Export Controls: Overview

    During the course of open research, Stanford faculty, staff and students will likely, at one time or another, intersect with federal regulations that impose access, dissemination, or participation restrictions on the transfer of items and information regulated for reasons of national security, trade sanctions policy, anti-terrorism, or non-proliferation. Stanford is fully committed to complying with all laws and regulations that pertain to the conduct and dissemination of our research, including U.S. export control regulations which are discussed in this overview.

    March 26, 2025

  • Export Controls: Research and Encryption

    Introduction As a general rule, code developed here at Stanford is the product of non-proprietary, fundamental research. To reinforce this, and to avoid difficulties with federal export control regulations, researchers should upload Stanford-generated encryption code onto a publicly available website as soon as possible. Access to the code must not include login requirements or other password or

    August 11, 2023

  • Export Controls: Temporary Exports

    TMP Overview Unlike the export of information resulting from fundamental research, tangible exports of equipment, materials, and laptops plus intangible exports of commercial software, encryption code, and disclosure-restricted technical information are subject to export control regulations. The dual use Export Administration Regulations, however, make an exception to export license requirements

    August 9, 2023

  • International Activity

    Introduction Stanford's commitment to providing a safe environment for everyone creates particular requirements for PIs in research laboratories. Labs at Stanford house chemicals, equipment, and other materials that can pose hazards to health. The proper management of these hazards is not only good lab management, it is also a regulatory requirement. Compliance and Operational Support Register

    July 8, 2024

  • Export Controls: Penalties

    Introduction This topic presents an overview of legal authorities and penalties for export control violations. The Export Administration Regulations The Export Administration Regulations (EAR) provides the following sanctions: Criminal Sanctions Willful Violations University A fine of up to the greater of $1,000,000 or five times the value of the exports for each violation. Individual A fine of up

    March 29, 2021

  • Academic Integrity and Undue Foreign Interference

    The Global Engagement Review Program( GERP) is a voluntary advisory process created to evaluate potential undue foreign influence risks in the context of maintaining Stanford research’s open and welcoming community. The program coordinates input from multiple offices that advise on various aspects of foreign engagements to assess risks related to undue foreign influence, research security and integrity.

    March 26, 2025

7 How Tos

  • How To

    Comply With Export Control Regulations When Hiring a Foreign National to Work at Stanford Under an H1-B Visa

    In order to comply with USCIS export licensing assessment requirements, DoR and Bechtel International Center have teamed up to incorporate an export control questionnaire ("Deemed Export Questionnaire") within Bechtel's H1-B Workflow. Because of the elevated compliance risk associated with export control matters, the Dean of Research has determined that only members of the Professorate, defined as

    September 11, 2024

  • How To

    Ship Dangerous or Hazardous Goods Outside the U.S.

    You may be in violation of Federal Law and create a public safety hazard if you ship biological materials, dry ice, lithium batteries, hazardous materials, or any other “Dangerous Goods” unless you have received specific training and the material is properly packaged and labeled. Complete training for shipping chemical or biological materials, or arrange for a certified hazardous materials shipper

    August 16, 2024

  • How To

    Ship or Hand-carry Stanford Owned or Controlled Equipment, Supplies, Software, Biological Material or Other Goods to Countries Outside of the U.S.

    Review the Stanford Export Controls Decision Tree to determine if your item is on an export control list. Contact Stanford’s Export Control Office if your item is on a list or if you need assistance. Next, screen your recipient and your recipient’s organization against US export control Restricted Party Lists. Finally, document your export by filing the appropriate export control form.

    August 9, 2023

  • How To

    Sign a Non-disclosure or Confidentiality Agreement That Is Export Control Compliant

    In some cases, non-disclosure requests are embedded in the content of several kinds of institutional agreements between the University and the sponsor or third-party. Examples of such institutional agreements include equipment or software purchases or loans, technology licensing, data sharing agreements, and material transfer agreements. In these kinds of institutional agreements, a Stanford

    May 19, 2021

  • How To

    Travel to Cuba, Iran, Syria, North Korea, or Sudan on Stanford University Business

    Immediately contact Stanford’s Export Control Office so it can be determined if you can travel to these countries without an export license. Cuba, Iran, Syria, North Korea and Sudan are subject to US financial and trade sanctions. Travel to and transactions with these countries are regulated. Read Memo from Ann Arvin, Vice Provost and Dean of Research

    August 9, 2023

  • How To

    Travel Outside the U.S. With a Stanford-owned Laptop, Cell Phone, PDA or Flash Drive

    Determine whether your travel will allow you to meet the terms and conditions set forth on the Annual TMP Certification for items 1 through 5 by completing the Temporary Export Property Checklist, since by signing the form you are becoming personally accountable for complying with those terms and conditions. If your travel will not allow you to meet the Annual TMP Certification's terms and

    August 9, 2023

  • How To

    Protect Your Computing Devices When Traveling Internationally

    When you travel internationally, the safeguards provided by the Stanford University computing environment are not available. Important data on devices such as laptops, notebooks, iPads, smart phones, MP3 players, thumb drives, SD cards, SIM cards, cameras must be properly protected. Furthermore, if you travel to countries that are known for computer and network-based espionage (e.g., network

    March 25, 2022

11 Glossary Terms

  • US Person

    A citizen of United States, a lawful permanent resident alien of the US, (a Green Card holder), a refugee or someone here as a protected political asylee or under amnesty. US persons also include organizations and entities, such as universities, incorporated in the US. The general rule is that only US persons are eligible to receive controlled items, software or information without first obtaining

    May 13, 2021

  • Reexport

    An actual shipment or transmission of controlled tangible items, software, or information from one foreign country to another foreign country. The export or reexport of controlled tangible items, software, or information that will transit through a country or countries, or will be unloaded in a country or countries for reloading and shipment to a new country, or are intended for reexport to the

    May 13, 2021

  • ITAR-listed

    Items, information, software (collectively "defense articles") and technical assistance ("defense services") specially designed or adapted for military use or which "provide a critical military or intelligence advantage." Defense articles include certain research satellites other and space science instruments. Defense articles and defense services are identified on the ITAR's US Munitions List

    November 17, 2021

  • Fundamental Research

    The concept of "fundamental research" was established by National Security Decision Directive 189 (see Related Items Below). NSDD 189 defines fundamental research as: "Basic and applied research in science and engineering where the resulting information is to be shared broadly within the scientific community, as distinguished from proprietary research and from industrial development, design

    May 13, 2021

  • Foreign Person

    Anyone who is not a "US Person" (see US Person definition on this page). Examples of foreign persons are students, post-doctoral scholars, or research staff in F-1 or J-1 status, and Stanford foreign national employees in H1-B status. A foreign person also means any foreign corporation, business association, partnership, or any other entity or group that is not incorporated to do business in the

    January 11, 2024

  • Export Controlled Use Technology

    Unpublished or disclosure-restricted dual-use information or software source code (binary code is okay) related to an export controlled item and required for the “operation, installation maintenance, repair, overhaul, and refurbishing” of an item or software. If technology released to a foreign national for use of an item or software does not meet all of these attributes, then it does not qualify

    May 13, 2021

  • Export Controlled Production Technology

    Unpublished or disclosure-restricted information or software source code (binary code is okay) related to an export controlled item and required in production stages, such as: product engineering, manufacture, integration, assembly (mounting), inspection, testing, quality assurance. Stanford-generated production technology or source code, as a result of university fundamental research, is not

    May 13, 2021

  • Export Controlled Development Technology

    Unpublished or disclosure-restricted information or software source code (binary code is okay) related to an export controlled item and required prior to serial production, such as: design, design research, design analyses, design concepts, assembly and testing of prototypes, pilot production schemes, design data, process of transforming design data into a product, configuration design

    April 9, 2021

  • Export

    To send or take controlled tangible items, software, or information out of the United States in any manner (including hand-carried), to transfer ownership or control of controlled tangible items, software, or information to a foreign person, or to disclose information about controlled items, software, or information to a foreign government or foreign person. The controlled tangible item, software

    April 9, 2021

  • Dual Use

    Items, information, and software that are primarily commercial or civil in nature but also have potential military applications. Dual use items that are identified on the Export Administration Regulation's Commerce Control List (CCL) have an Export Control Commodity Number (ECCN) and are of elevated strategic concern. Dual use items that are subject to regulation but are not identified on the CCL

    May 13, 2021

  • Deemed Export

    A release of export controlled technology or software source code to a Foreign Person in the US. A regulated export is thereby "deemed" to take place to the Foreign Person's home country or last country of citizenship. Export controlled technology is "released" for export either a) when it is made available to Foreign Persons for visual inspection (such as reading technical specifications, plans

    May 13, 2021

12 Forms & Tools

  • Guide

    Strong Encryption Export Controls

    Export Administration Regulations (EAR) The release of publicly available strong encryption software under the EAR is tightly regulated. However, a License Exception TSU (Technology and Software - Unrestricted) is available for transmission or transfer of the code outside of the US. Strong dual-use encryption, addressed in Category 5 Part II of the EAR's Commerce Control List (CCL) at 5A002

    August 9, 2023

  • Guide

    Encryption Export Controls: International Traffic in Arms Regulations (ITAR)

    ITAR encryption controls are located in three primary Categories on the US Munitions List (USML ). Category XI - Military Electronics Subparagraph (b) - Encryption software designed or modified to: Generate spreading code for spread spectrum or hopping code for frequency agility (does not include fixed code techniques); Use "burst" (time compression) techniques; Use "burst" (time compression)

    April 7, 2023

  • Guide

    Export Controls Reference Guide

    Find information about what you need to know before traveling abroad in this reference guide.

    January 10, 2022

  • Reference List

    Export Controls: Forms

    In most cases, forms related to export controls can be filed electronically using the links below. Departments or programs must keep soft or hard copies of all export documentation, including financial records and shipping documentation (i.e., FedEx Air Waybills, Purchase Orders from Stanford Express, Commercial Invoices, etc.) and Stanford Certifications in their research project files for a

    February 4, 2025

  • Decision Tree

    Export Controls Decision Tree

    The decision tree is a questionnaire to determine whether export controls are applicable to your activity. The tool walks users through a series of "Yes" or "No" questions that ask about sharing, shipping, transmitting or transferring items, information, or software in the context of your situation. The responses lead to a determination of whether an export control license may be applicable.

    March 26, 2025

  • Export Controls: Restricted Party Screening

    This tool evaluates the potential export/trade sanctions and foreign engagement compliance risks associated with persons and entities with whom we wish to partner.

    December 7, 2023

  • Guide

    Export Controls: Openness in Research Checklist

    Introduction Guidelines for ensuring that agreements comply with Stanford's Openness in Research policy. Applicability No program of research that requires secrecy may be conducted at Stanford, unless it meets one of the exceptions set out in the University's Openness in Research policy. Use this questionnaire when reviewing: requests for proposals or project solicitations program award notices

    August 9, 2023

  • Checklist

    Export Controls: Tools and Checklists

    General Tools and Checklists The following are important resources in the general area of export controls. They will help to introduce the topic, as well as provide the information needed in specific situations. Export License Certification Reference Guide A comprehensive summary of Stanford export control policies, position responsibilities, resources, best practices and documentation

    July 8, 2024

  • Export Controls: Sample Letters and Clauses for Faculty, Students, and Staff

    Downloadable letters and agreement language can be found below in Related Items section and can be used by faculty, students, and staff at Stanford in situations where correspondence is needed to document Stanford's exclusion from, or adherence to, US export control regulations. Fundamental Research Letter This letter will be of assistance for international travel by Stanford foreign national

    August 9, 2023

  • Reference List

    Export Controls: Chemicals, Chemical Agent Precursors, Propellants, Explosives, and Energetic Materials

    Chemicals, Chemical Agent Precursors, Propellants, Explosives, and Energetic Materials The ITAR controls certain military-related chemicals, chemical agent precursors, propellants, explosives and energetic materials at Category V and Category XIV of the US Munitions List (USML). Likewise, the EAR regulates exports of certain dual use propellants and chemicals at ECCNs 1C111 and 1C350, respectively

    August 9, 2023

  • Reference List

    Export Controls: Pathogens and Toxins

    Pathogens and Toxins Department of Commerce dual-use export control-listed pathogens and toxins are listed below. These pathogens and toxins are found on the Commerce Control List (CCL) in Category 1 at ECCNs 1C351 through 1C360. Please note that export controls also apply to genetic elements and genetically modified organisms that contain DNA associated with the pathogenicity of these biological

    August 11, 2023

  • Reference List

    Export Controls: Munitions and Dual-Use Items

    Munitions and dual-use Items items, information, and software subject to U.S. Export Control laws and used in a university environment are generally categorized on one of two lists: U.S. Munitions List (USML )published by the U.S. State Department in its International Traffic in Arms Regulations (ITAR), and the Commerce Control List published by the U.S. Commerce Department in its Export Administration Regulations (EAR). Learn more.

    March 26, 2025

9 Announcements

  • US Trade Sanctions Requirement Memo from Ann Arvin

    Subject: US Trade Sanctions on Crimea, Cuba, Iran, Syria, Sudan and North Korea - Stanford University Notification, Review and Pre-­Approval Requirement Date: Wednesday, January 14, 2015 at 1:40:14 PM Pacific Standard Time From: Patti McCabe (sent by abc-­research ) To: abc-­ research@lists.stanford.edu Sent on behalf of Ann Arvin, Vice Provost and Dean of

    August 11, 2023

  • DoD Memorandum on Protecting Exemptions for Fundamental Research

    View this memo from the DoD.

    May 25, 2021

  • Reminder - Export Controls Documentation Requirements

    View this memo from Ann Arvin.

    May 25, 2021

  • Export Controls Compliance and International Shipments Memo from Ann Arvin

    To: Stanford Faculty and Staff From: Ann Arvin, Vice Provost and Dean of Research Date: June 10, 2013 Re: Export Controls Compliance Dear Colleagues, A recent Settlement Agreement for $100,000 between the University of Massachusetts and the U.S. Department of Commerce’s Office of Export Enforcement (htt p://efoia.bis.doc.gov/exportcontrolviolations/E2306.PDF) underscores the importance of export

    July 31, 2023

  • Export Controls Document Requirements

    Date: April 20, 2009 To: Faculty and Research Administrators From: Ann Arvin, Vice Provost and Dean of Research Subject: Documentation Requirements – Export Controls As part of our ongoing effort to facilitate export control compliance across the university, and in conjunction with the recent rollout of Stanford’s new export control website at export.stanford.edu, my office has updated its

    August 2, 2023

  • Reminder - Export Controls Requirements

    March 9, 2007 To: Stanford Principal Investigators From: Ann Arvin, Vice Provost and Dean of Research Subject: Reminder - Export Control Requirements Stanford is committed to adhering to all applicable export control laws and regulations that pertain to the conduct and dissemination of our research and to the export of tangible items such as equipment, components or materials. Stanford will not

    August 3, 2023

  • Memo: Export Control Documentation Requirements

    Date: April 20, 2009 To: Faculty and Research Administrators From: Ann Arvin, Vice Provost and Dean of Research Subject: Documentation Requirements – Export Controls Stanford's Openness in Research Policy expresses our institutional commitment to "the principle of freedom of access by all interested persons to the underlying data, to the processes, and to the final results of research" (reinforced

    August 11, 2023

  • Travel to US Sanctioned Countries (Iran, Cuba, Syria, Sudan, North Korea and the Crimean Region of the Ukraine)

    Sent on behalf of Ann Arvin, Vice Provost and Dean of Research Dear Colleagues, As we enter this busy summer travel period, I would like to remind you that the US Government continues to impose trade sanctions against Iran, Cuba, Syria, Sudan, North Korea and the Crimean Region of the Ukraine. Travel to these countries, as well as research-related activity in these countries, remains tightly

    August 3, 2023

  • Memorandum on Relationships with Entities Identified as Presenting Elevated Export Control or Information Security Risks

    This memo addresses steps that must be taken by Stanford faculty in advance of initiating a research collaboration, industrial affiliate relationship, or other institutional research relationship with an entity (“Entity”) that the Dean of Research (DoR) office, together with the Information Security Office has determined presents elevated export control or information security risks. The Export

    March 12, 2025