Identifies the requirement for the original recipient of export controlled articles or data to determine the eligibility of others to access such items or data without an export license; addresses the potential applicability of specific export license exemptions and exceptions; sets forth the requirement that the original recipient of export controlled articles or data document all transfers when export controls apply.
1. Export Controls on Individual Eligibility as a Recipient
Generally, federal regulations require that only US persons as defined in RPH: Definitions may be provided with export-controlled items, software code or information without having to obtain an export license. Nonetheless, there are some specific exemptions (ITAR) and license exceptions (EAR) available to those within the University community that may be useful. It is extremely important to keep them in mind should it become necessary to share any export-controlled items, software code or information beyond the original recipient.
In addition, records must be kept in order to demonstrate compliance.