Buffalo State Export Control Compliance Policy

It is the policy of Buffalo State that instruction, research and services will proceed openly and without restrictions and prohibitions on the publication and dissemination of the results of academic research activities.  In this context it is also essential that all employees, professors, students, researchers and collaborators comply with U.S. export control laws. 

U.S. export control laws, including the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), and U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) prohibit the unlicensed export of certain technologies, information and software to certain countries or people from those countries.  Under the "deemed export" provision, these laws apply to foreign nationals living in the United States, defining a deemed export as the transferring of technology, information and/or software to foreign nationals living in the US.  Thus, Buffalo State has developed screening processes and questionnaires in order to identify when a license might be necessary.  The need for a license is dependent on two factors:  the type or research activity and the home country of individuals involved in the research.  The screening processes occur at the point of hire, through the annual report process where employees report on their activities of the past year and plans for the upcoming year, and through a travel authorization form for people whose Buffalo State work leads them to travel overseas.  (See the other sections of this site for more information about these processes.)  Finally, it is important to recognize that many standard activities of faculty and staff fall under one of the various exclusions to these laws.  (See "Exclusions" )

Because these laws are both new and complicated, Buffalo State is committed to educating its employees, professors, students, researchers and other collaborators about U.S. export controls laws and regulations and their particular application within a university research setting.  As part of our ongoing commitment to export control compliance and education, we have compiled much of the relevant information on this site as well as posted some presentations explaining some of the finer points about export controls.

An Introduction to Export Controls:  What Principal Investigators Need to Know (Sandra Cochran)

Deemed Export Controls Training #1 (Karen Server)

Deemed Export Controls Training #2 (Karen Server)

Buffalo State will fully comply with U.S. export control laws while ensuring that, to the extent possible, university instruction and research is conducted openly and without restriction on participation or publication. To this end, Buffalo State will ensure that, unless unavoidable, information generated during the performance of any university research, including sponsored contract activities, qualifies for the Fundamental Research provisions of applicable export control laws.

Policy Scope: This policy and related guidelines are applicable to all members of the Buffalo State community.