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 Memorandum on Export Documentation Requirements. This Memorandum explains the required submission of export control Certifications that document our export control due diligence. The Certifications are found on Stanford’s Export Control Forms page.
As you know, Stanford is committed to complying with all applicable export control laws and regulations that pertain to the conduct and dissemination of our research and its products. Export controls, when applicable, may require Stanford to receive authorization from the US Government in the form of an export license. An export license permits export controlled tangible items or software to be sent outside of the US, or for export controlled information or software code to be shared with foreign persons in the US ("deemed exports") or abroad.
Most of the information and software code that Stanford ships abroad or shares with its foreign colleagues and research partners, when university-generated public domain basic and applied research, is excluded from export licensing requirements under a fundamental research “safe harbor”. Likewise, most of the tangible items that Stanford ships internationally do not require export licenses because they are neither identified on Government export control lists nor destined for countries or individuals subject to US embargoes or sanctions. Nevertheless, in spite of the limited occasions in which export licenses apply to its research activities, Stanford is required to demonstrate its due diligence when export regulations do apply and to document its adherence to these laws, including those circumstances when export licenses are not required.
Stanford’s Export’s Controls Decision Tree is a highly useful web-based, interactive tool that can help identify those circumstances. In addition, Stanford’s Export Control Officer is available to provide export license determinations for particular situations and to recommend the appropriate documentation when export licenses do not apply.
I encourage each of you to review the Memorandum and to explore the variety of resources and tools that are available on Stanford’s export control website. If you have questions or concerns, Stanford’s Export Control Officer, Steve Eisner (email@example.com, 4-7072), will be glad to address them.
Ann M. Arvin, M.D.
Vice Provost and Dean of Research