Export Controls

Who We Are

At the core of Stanford’s principles regarding research - the ability for its faculty and students to engage in research in an open environment - is its Openness in Research policy. Stanford is committed to the principle of freedom of access by all interested parties to the underlying data, to the processes and to the final results of research. In keeping with this commitment, Stanford will not accept research agreements that limit the publication of results or that limit the participation of researchers in the intellectually significant portions of a project on the basis of citizenship. 

During the course of such open research, Stanford faculty, staff and students will likely 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 these U.S. Export Control regulations, and all laws and regulations that pertain to the conduct and dissemination of our research. 

The director of export control serves under the Vice Provost and Dean of Research as a resource to the Stanford research community in providing information about export control policy, helping researchers determine which regulations apply to their research engagements and navigating the process for acquiring an export license if needed. 

Services

Export controls govern the shipment, transmission, or transfer of regulated items, information and software to foreign countries, persons or entities.  Most of the information or software that Stanford shares with its colleagues and research partners is not subject to export controls or trade sanctions. The majority of tangible items that Stanford exports, like materials, prototypes, components, or equipment, do not require export licenses since they are generally not destined to countries of concern or to individuals or organizations subject to U.S. embargoes or sanctions. 

However, all Stanford personnel are required by university Exports Control Policy to demonstrate their due diligence and to document their adherence to U.S. export controls and trade sanctions laws when such laws apply.

Does Export Control Apply to Your Research?

One way the export controls team helps researchers determine if the controls apply to their work is through an Export Control Decision Tree. This self-service platform guides researchers through a series of questions regarding their research engagement to produce guidance on further steps, if any, they need to take to meet the policy.

When export controls apply - for example, when researchers use disclosure-restricted technical information to generate research or hand carry items outside the U.S. - the export of regulated items, information, or software may require an export license. An export license permits "controlled" tangible items or software to be sent outside of the U.S., or controlled information or software code to be shared with foreign persons, either in the U.S. or abroad.  

Export control regulations are complex and constantly evolving. The VPDoR glossary below introduces common export control terms and concepts in easy-to-understand terms. Stanford relies on proper documentation in order to make use of exclusions and exemptions from licensing requirements. Recordkeeping is essential for those involved in research where it may be necessary to ship research articles outside the U.S. or to share export-controlled information provided by third parties, including vendors, subcontractors and collaborators.

Find your Export Controls officer for your school or department in this list.

Brandon Barnhill

Our Team

Brandon Barnhill

Export Control Director

barnhib@stanford.edu

Learn More

What Items Do Export Controls Usually Cover? 

When export controls apply, they are frequently, but not exclusively, associated with items, information, and software code within the following general areas: 

  • Chemical, Biotechnology, and Biomedical Engineering  
  • Materials Technology 
  • Remote Sensing, Imaging, and Reconnaissance  
  • Navigation, Avionics, and Flight Control 
  • Robotics 
  • Propulsion System and Unmanned Air Vehicle Subsystems  
  • Telecommunications/Networking 
  • Nuclear Technology 
  • Sensors and Sensor Technology 
  • Advanced Computer/Microelectronic Technology  
  • Information Security/Encryption 
  • Laser and Directed Energy Systems 
  • Rocket Systems 
  • Marine Technology 

Glossary of Commonly Used Terms

A Selection of Federal Export Control Regulations 

Here is more information on the export control regulations of three federal agencies:

United States Department of State - Directorate of Defense Trade Controls

The International Traffic in Arms Regulations (ITAR) govern "defense articles and defense services" which are defined as items, information, software (defense articles) and technical assistance (defense services) specially designed or adapted for military use or which "provide a critical military of intelligence advantage." Defense articles include certain satellites and spacecraft.  

Defense articles and defense services are identified on the ITAR's US Munitions List. ITAR-listed items that are not the tangible products of university fundamental research generally require a license for campus access and use by all foreign persons.

U.S. Department of Commerce - Bureau of Industry and Security

The Export Administration Regulations (EAR) govern "dual use" items and information predominantly civilian in character but having military applications. Dual use items that are identified on the Export Administration Regulations 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 are termed "EAR99." 

Dual use items may require an export license depending on the item, the recipient, the recipient's citizenship or country of destination, and the item's application.

U.S. Department of the Treasury - Office of Foreign Assets Control

The Office of Foreign Assets Control Regulations (OFAC) administers and enforces trade embargoes and economic sanctions. The lists of sanctioned countries and Specially Designated Nationals (SDNs) is available on its website.