Harvard is committed to complying with applicable U.S. laws and regulations pertaining to exports of items, services and technology by or on behalf of the University. The Harvard policy statement (pdf) applies both to exports outside the U.S., as well as to exports to foreign nationals within the U.S. The Vice Provost for Research (VPR) oversees Harvard’s compliance with U.S. export-control laws and regulations. The VPR and the University’s Chief Research Compliance Officer co-chair the Harvard University Export Control Council that reviews and advises the VPR on export control issues.
Because awareness and oversight of Export Controls are best accomplished at the local level, each School or Institute has an Export liaison, designated to answer questions and oversee the implementation of compliance procedures within their respective schools, centers, laboratories and departments.
Assistance is available from the export liaisons, as well at the Office of the Vice Provost for Research, depending on the nature of the export controlled activity. Each of the following pathways requires you to assess applicability of export controls and offers assistance, if needed:
Identifying Potential Export Control Issues
- Before beginning any sponsored research project, you should reference the Checklist included in the Procedures for flagging EC Issues Guidance, to determine how to spot issues and whom to contact with respect to potential issues.
Shipping Materials Overseas
- Any item that is sent from the United States to a foreign destination is an export. “Items” include commodities, software, technology, and information.
- The export of controlled items, information or software may require approval from the U.S. government in the form of an export license. An export license permits controlled tangible items or software to be sent outside the U.S. or controlled information or software to be shared with foreign persons in the U.S. or abroad.
- Before carrying, shipping, or otherwise sending materials outside of the United States, you should consult your School or Institute’s Export liaison and to determine whether an export license is required.
Traveling to, or Collaborating with Colleagues, Overseas
- Before traveling to countries that may be the subject of sanctions, collaborating with a foreign national outside of Harvard University or any person or entity outside of the United States, or presenting your research at an international conference, check the following sanctions lists:
- Dept. of Treasury Sanctioned Countries
- Dept. of State Country Policies and Embargoes List
- Dept. of Commerce Lists to Check
- If you expect that your research may involve or be shared with any individual or entity on any of those lists, you must confer with your School or Institute’s Export Liaison or the University Export Control Director to determine whether a license is required for your planned activities.
- You should also reference the points to consider when travelling abroad in the Foreign Travel Issues section of this site.
Taking Computers or Other Electronic Devices Aboar
- Before traveling abroad with a laptop or GPS equipment, you should reference the International Travel Guidance: Electronic Devices and Encryption Software as well as the Information Security Office Advisory for Travelers.
Outsourcing of IT Services and Cloud Computing
- Outsourcing of IT Services and use of cloud computing may lead to export control related issues; to assist those planning to use outsourced IT Services an Export Controls and IT Outsourcing Guidance has been prepared to provide you with more information.