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 University’s Chief Compliance Officer oversees Harvard’s compliance with U.S. export-control laws and regulations and chairs the Harvard University Export Control Council that reviews and advises the OVPR on export control issues.
Because awareness and oversight of Export Control are best accomplished at the local level, each School or Institute has an Export Control Officer, designated to answer questions and oversee the implementation of compliance procedures within their respective schools, centers, laboratories and departments.
Below are some common areas where export control issues may arise:
Shipping/Carrying 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 the International Shipping Guidance and your School or Institute’s Export Control Officer 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, conduct an SDN screen.
SDN screens may also need to be conducted when enrolling foreign nationals in:
- Professional or continuing education courses,
- On-line courses or executive education programs, or
- Otherwise providing services or receiving funds from foreign nationals
- The Export Control Guidance on SDN screens provides further information on how to conduct SDN screens, and how to proceed if a screen results in a positive match.
- You should also reference the points to consider when travelling abroad in the Foreign Travel Issues section of this site.
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 Control Guidance Document for Outsourcing IT Services has been prepared to provide you with more information.