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Export Control Compliance

Export Controls Compliance and Tulane University

Tulane University is at the forefront of scientific discovery and ingenuity and, as such, the information that research yields is coveted by others and sensitive to potential theft or misuse. While Tulane is fully committed to the idea that the research it undertakes should be freely disseminated and accessed for the betterment of humanity and scientific advancement, it is also fully committed to following the laws and regulations of the United States and other countries around the world to prevent unauthorized disclosures.

The goals of Export Compliance are to:

  • Protect the United States and our allies’ national security
  • Advance foreign policy goals and obligations around the world
  • Prevent/Limit the diversion of sensitive data or technologies

The shipment or transfer of ‘items’ subject to export regulations to foreign nationals or foreign institutions/business falls within the purview of the U.S. export regulations. Items might include hardware, technology, software, word of mouth assistance among others.

The Tulane University Export Compliance Program Manual (“Manual”) is intended is to provide guidance on U.S. Export Control laws and regulations, to identify key export compliance issues related to research, education, and all other activities conducted within a university setting, and to describe how compliance policy is to be implemented. The procedures outlined herein serve as Tulane University’s program of internal controls, safeguards, and educational measures designed to minimize risk of potential violations of all applicable export control laws and regulations and institutional policy. The U.S. export control agencies place responsibility on the University to understand and ensure compliance with export control laws and regulations.

Tulane Export Compliance Program Manual

Much of the technology, information or software that Tulane University has access to or that it shares with research partners and other parties is not subject to export controls due to government regulations granting exceptions in regard to ‘fundamental research’ or ‘educational information’. However, these exceptions have limitations; for example, exchanges may only occur within the United States. Care should be taken when considering whether technology, information or software is subject to export regulations or not.

Fundamental Research exceptions cannot be claimed in cases where the University:

  • Accepts a grant or contract clause where the participation of foreign persons is prohibited
  • Accepts a grant or contract clause that gives the sponsors rights to publish the results of research; or
  • Accepts a grant or contract clause that restricts outside participation in the research and/or limits access or disclosure of the research in question

If the information or activities do not qualify for transfer under the exceptions available, there might be licensing requirements that must be met before a transfer may occur. Licensing requirements are based on the information or items to be exported, the country of destination, and the persons or entities to which the information or items will be sent.

Activities at Tulane that might meet licensing requirements could include:

  • Information marked as proprietary or labeled that dissemination is prohibited without approval
  • Research collaborations involving international parties
  • International shipments of items, equipment, software, or technology
  • Overseas travel, including conferences
  • Personal travel would not require licensing unless information or items requiring a license would need to be shipped or accessed while abroad
  • Providing financial assistance to a person or entity that is considered a blocked or sanctioned party in an embargoed country
  • Providing professional services or assistance to a person or entity that is a blocked or sanctioned party or individual from an embargoed country.

This office stands by ready to assist with your questions or concerns, assisting with determining licensing requirements, obtaining licenses and will ultimately provide you with the tools and education needed for prudent decision-making. This website is under development and will be updated regularly. Please contact me if you have any questions on any of the above or suggestions for the webpage.

Christopher M. Dressler
Tulane University - Export Control Compliance Officer
office phone: 504.988.7919
mobile phone: 616.350.4136
fax: 504.988.1238 
email: cdressler1@tulane.edu or exportcontrols@wave.tulane.edu
web: https://research.tulane.edu/compliance
scheduling: kleger@tulane.edu or 504.988.1147
location: 1440 Canal Street, Room 949-H, Mail Stop #8401, New Orleans, LA 70112