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Research Responsibilities and Compliance

University Activities

The Ohio State University conducts innovative research and fosters a research environment conducive to the creation and dissemination of knowledge for the public good. As part of this mission, the university continues to expand its research and other collaborative efforts with foreign countries and their citizens. All such activities may be subject to federal regulations covering certain exports with destinations and persons outside of the United States. In some cases, these regulations also apply to non-United States citizens at the university and within the United States.

Your research or activities may be subject to export controls if you:

  • Will interact with a restricted party, party of concern or sanctioned region
  • Will be receiving or generating export controlled technical data/technology or items
  • Are notified that you will be receiving controlled items
  • Anticipate the potential to treat your data as confidential or proprietary
  • Are developing something that has a military and civilian application or a purely military application
  • Require a physical export 
  • Are engaging in international field work
  • Are going to a sanctioned country or region
  • Are taking Ohio State items and equipment abroad
  • Are traveling with proprietary software (software that includes encryption and/or other complex software)
  • Will engage in an international collaboration

University Interactions

Interactions can be research collaborations, educational exchanges, financial transactions, etc. 

Restricted Parties

Foreign and domestic individuals, companies and organizations that the United States government has designated as acting contrary to the national security or foreign policy objectives of the United States. These lists are publicly available; however, Ohio State has software which can check these lists very quickly and maintain records for screenings performed at the university. There are many people at Ohio State, in addition to the Office of Secure Research that can screen these parties.

Parties of Concern

Parties of Concern are identified in press reports, by intelligence or law enforcement agencies or colleagues as presenting a higher risk from an export control, security or reputational perspective. The Office of Secure Research maintains an internal list of these parties.

Sanctioned Regions

Sanctions can either be comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals.

Geographies with either comprehensive or selective sanctions are: Balkans, Belarus, Burundi, Central African Republic, Cuba, Democratic Republic of Congo, Iran, Iraq, Lebanon, Libya, Mali, Nicaragua, North Korea, Somalia, Sudan, Darfur, Syria, Ukraine/Russia, Venezuela, Yemen and Zimbabwe.

The highest risk of these are: Cuba, Iran, North Korea, Sudan and Syria.

Ohio State faculty, staff and students that are citizens of Cuba, Iran, North Korea, Sudan and Syria are authorized to perform the activities for which their visas are approved; however, sharing controlled technical data/technology to them is more challenging from a regulatory perspective.

Deemed Exports

Even when Ohio State is not sending any technical data/technology or physical items to another country, certain research activities taking place in the United States may still be subject to export control regulations. A deemed export occurs when controlled technical data/technology is transferred or released to a foreign person in United States. Because the majority of Ohio State’s activities are exempt from export control regulations, it is important to be aware when activities are subject to the regulations so that Ohio State can ensure compliance.

Receiving or Generating Data, Technology or Items

Controlled technical data/technology and items can end up on campus in a variety of ways. We can receive it from other parties or we can generate it. Sharing export controlled technical data/technology (even the technical data/technology associated with physical items) with foreign persons here in the United States is a deemed export.

Receiving Controlled Technical Data/Technology

Through our contractual agreements, Ohio State typically asks that the sending party notify us prior to providing us with export controlled technical data/technology. 

Receiving Controlled Items

Through our contractual agreements, Ohio State typically asks that the sending party notify us prior to providing us with controlled items.

Certain toxins, chemical or biological materials are highly controlled

  • Human, animal and plant pathogens and “toxins
  • Chemical Weapons Convention (CWC) Schedule 2 and 3 chemicals and families of chemicals
  • Genetic elements and genetically modified organisms related, vaccines, immunotoxins, medical products, diagnostic and food testing kits and the technical data/technology for disposal related to the above

Developing Controlled Technical Data/Technology

Contractual restrictions around our ability to freely publish not only threatens our academic freedom, it can also trigger our research results to be subject to export control regulations.

Even if the technical data/technology is developed on a project that qualifies as Fundamental Research, if a decision is made to treat that data as confidential or proprietary, the university loses its ability to claim Fundamental Research.

Fabricating Controlled Items

All physical items fall under export control regulations at one level or another. Most physical items on campus would not trigger export concerns unless they are being physically sent to another country.

Items developed for military purposes or that have both a military and civilian application likely have deemed export implications.

Physical Exports

Whenever a physical item enters the United States, regardless of its origin, it is subject to export control regulations when it leaves the United States. Our office will determine license requirements prior to physically exporting any items.

Physical exports happen:

  • During international travel when physical items are transported (regardless of whether they are sent ahead of time or hand carried)
  • During international travel when electronic devices are brought containing controlled technical data/technology
  • When items are shipped (in any quantity) to another country by any method (even if the item is returning to its country of origin).

International Field Work

Export Controls may apply when:

  • Research takes place outside of the United States. The research results research taking place outside of the United States may not qualify as Fundamental Research.
  • Equipment or items are taken or shipped out of the country. Even if the items are coming back to the United States, this would be considered a Physical Export.

International Travel

International Travel can intersect with export control regulations based on where you are going, who you will be interacting with and what you are taking with you.

If you are going to a sanctioned country or region (Cuba, Iran, North Korea, Sudan, Syria, the Crimea region of Ukraine), contact us as soon as possible so that we can review the regulations and ensure that your travel activity is covered by a General License.

It is important to ensure that you do not export restricted information or provide any type of assistance to a restricted party. Our office can quickly determine if parties you intend to visit or collaborate with are on a restricted party list.

If you are taking Ohio State items and equipment, even temporarily, those physical items are being exported. Refer to the chart below for the ECCNs for equipment most commonly taken abroad. If you are planning to take equipment that is not listed in the chart below, please contact us so that we can determine whether an export license is required prior to your trip. 

Most commercially available basic software can be exported without a license. However, proprietary software, software that includes encryption and/or other complex software may require an export license and should be reviewed by the Office of Secure Research. 

ECCNs for Common Travel Items*

*Do NOT use this chart for travel to a sanctioned region like Cuba, Iran, North Korea, Sudan, Syria or the Crimea region of Ukraine.

Item ECCN# Licensed Authority

Dell Laptop (no encryption)

4A994

No Licensed Required (NLR)

Mac Laptop

5A992

No Licensed Required (NLR)

IPhones & IPads

5A992

No Licensed Required (NLR)

Jump/Flash Drive (most)

3A991

No Licensed Required (NLR)

Android Cell Phone/Tablets

5A992

No Licensed Required (NLR)

Garmin GPS

7A994

No Licensed Required (NLR)

International Collaborations and/or Presentations

Ohio State has launched the International Risk Assessment Tool to assist the research community to consistently and transparently identify international activities that may present an elevated risk to the university. The tool considers the unique factors of each engagement such as the specific activity, the level of Ohio State engagement, the location of the activity, and entities and personnel involved. This tool facilitates the conduct of international activities by allowing low risk activities to proceed without delay or extensive compliance checks, while flagging those potentially problematic activities for additional institutional review and approval.

In general, collaborations between university personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve any one of the following:

  • Restricted Parties
  • Parties of Concern
  • Persons in sanctioned countries
  • The shipping of physical items to a foreign party
  • The exchange of export controlled technical data/technology

Before engaging in an international collaboration, the university needs to determine if export licenses are required and to verify that the foreign individual and/or organization are not blocked or sanctioned parties. Ohio State faculty, staff and students are encouraged to complete the International Risk Assessment Tool prior to engaging the Office of Secure Research for additional review.

Disclosure of Outside Activities

Ohio State requires all university research personnel who are appointed to a sponsored project or are participating in human, animal or biosafety research protocols to complete an annual disclosure of all outside activities related to their institutional responsibilities. To better address federal concerns regarding foreign talent recruitment programs, the disclosure process was revised in 2019 to require disclosure of any external relationships that are related to a “foreign talent program.” This process is currently being enhanced to facilitate the reporting of affiliations, financial interests, and research support involving foreign entities. 

Early Disclosure Checklist

Prior to seeking external research funding, Ohio State researchers need to provide specific details about their proposed project by completing an online form known internally as ePA-005. These details include information that can help assess whether the project may involve potential export control issues, conflict of interest issues, infectious or select agents, security classification requirements and other potential compliance concerns. This form allows the appropriate university personnel to proactively identify and manage potential compliance risks early in the research process.

Presentations at Meetings / Conferences

When new information is presented at meetings or conferences open to the public in the United States, that information is released into the public domain. As such, it is important to be sure that all presentations at meetings or conferences contain data that is exempt from export control regulations. This includes information generated as the result of Fundamental Research or is already publicly available. If information was generated that does not qualify for as Fundamental Research (i.e. has restrictions on who can perform the research, typically restrictions on citizenship and/or requires sponsor approval prior to publication), approval from the sponsor must be obtained prior to releasing that data into the public domain.

Foreign Person Visitors

Visits from representatives of foreign governments are managed by the Office of International Affairs and the Office of Government Affairs to ensure appropriate security and controls are in place and that visitors are not provided access to sensitive areas of campus.

Foreign Visiting Scholars

As all university research personnel, foreign visiting scholars sponsored by Ohio State are subject to university policies and procedures regarding export control compliance, institutional data, and responsible use of computing and network resources, among others. Those scholars on H1-B visas are reviewed by the Office of International Affairs and any concerns identified are shared with appropriate personnel. In some cases, prior to facilitating a visa for a visiting scholar, additional security or control measures may be implemented.