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.
All communications with U.S. licensing authorities shall be made through the VPR or a person designated by the VPR as an “empowered” official. Researchers seeking to ship or transport an item to another country or disclose technology to a foreign national are responsible for determining whether such item or technology is subject to export-control regulations. Investigators should be aware also that as of February 20, 2011, the U.S. Citizenship and Immigration Services (USCIS) Form I-129 will include a "Deemed Export Attestation" that requires the petitioner (i.e. the University) to certify whether visa petitions for certain classes of foreign person work visas will require a license or other government authorization for the release of export-controlled technology or technical data to the foreign person in the United States during their employment. To meet this requirement, the University’s visa application now includes a “Deemed Export Certification.” This certification must be signed by the Principal Investigator or Department Chair and the School’s Compliance Officer, attesting whether or not a deemed export license is required prior to the release of technology or technical data to the foreign person. For further guidance, please click here (pdf) or contact one of the individuals listed on the right.
Because awareness and oversight of Export Controls are best accomplished at the local level, the members of the Council are expected to oversee the implementation of compliance procedures within their respective schools, centers, laboratories and departments. Some Harvard departments and centers, such as The Office of the Provost and the Harvard-Smithsonian Center for Astrophysics, have well-established organizational export control procedures that are additive to those of the University.
Any questions regarding compliance or Harvard’s policies and procedures should be directed to the Vice Provost for Research.