| Title: | Export Control and Economic Sanctions Policy |
|---|---|
| Policy Owner: | Office of the Vice President for Research |
| Applies to: | Workforce Members, Students, Others |
| Campus Applicability: | All Campuses |
| Approval Date: | November 19, 2025 |
| Effective Date: | November 19, 2025 |
| For More Information, Contact | Chief Research Security Officer, Research Security |
| Contact Information: | exportcontrol@uconn.edu, or (860) 486-3619 |
| Official Website: | https://ovpr.uconn.edu/services/research-security/export-control/ |
BACKGROUND
Export control and economic sanctions regulations aim to protect the national security, foreign policy, and economic interests of the United States. Export control regulations govern how certain information, technologies, and commodities can be transmitted overseas or to a foreign national on U.S. soil. Economic sanctions regulations restrict transactions with certain countries, institutions, and individuals. The scope of these regulations is broad: they cover exports in virtually all fields of science, engineering, and technology, apply to research activities regardless of the source of funding, and impose restrictions on activities by U.S. persons that occur outside the United States. These laws are collectively referred to as “Export Control Laws.” The University of Connecticut (UConn) encourages and supports open research and the free exchange of ideas. Although most university activities and research are exempt from export control laws, UConn engages in some activities, research, and the development of new technologies that are subject to Export Control Laws. Failure to comply with these laws can have serious consequences, both for the institution and for the individual researcher.
PURPOSE
To define the standards and responsibilities for complying with U.S. Export Control Laws and embargo regulations in all university activities, including research, instruction, travel, and the handling of controlled materials and information.
DEFINITIONS
Export Control Laws: Laws and regulations implemented by the U.S. Department of Commerce through its Export Administration Regulations (EAR), the U.S. Department of State through its International Traffic in Arms Regulations (ITAR), as well as embargo regulations imposed by the U.S. Treasury Department through its Office of Foreign Assets Control (OFAC).
APPLIES TO
This policy applies to all workforce members, students, and all other individuals working on all University campuses, including UConn Health.
POLICY STATEMENT
UConn is committed to compliance with Export Control Laws.
The Office of the Vice President for Research (OVPR) is the designated authority charged with compliance oversight of the U.S. export control and economic sanctions requirements for UConn and has final authority on such matters.
Individuals acting on behalf of the University, including faculty, staff and students, are responsible for complying with applicable Export Control Laws, including requirements related to international travel, the proper handling, transfer, access, storage, control, and dissemination of export controlled hardware, software, information, technology, and technical data to destinations and persons outside of the U.S., as well as in some cases, to foreign nationals at the university engaging in instruction, conducting research, or providing service activities.
The University typically conducts fundamental research in basic and applied science or engineering, which is widely and openly published and made available to the scientific and academic community. This allows for the Fundamental Research Exclusion, which means the research results are exempt from Export Control Laws. But Export Control Laws could apply if the research is not considered fundamental research, or if the research has restrictions on publication, foreign national participation, or restricted access to/disclosure of research results. Please contact the Export Control Office if you have any questions on whether Export Control Laws apply to your particular activity.
The University will not permit or support travel to any country subject to a comprehensive U.S. Government embargo (as set forth in the UConn International Travel procedure), unless the travel falls within the scope of a license or exception granted by law and is reviewed and receives written approval in advance by the OVPR Export Control Office.
ENFORCEMENT
Violations of this policy and any related procedures may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.
The civil and criminal penalties associated with violating Export Control Laws can be severe, ranging from administrative sanctions including loss of research funding, to monetary penalties, and imprisonment.
PROCEDURES
Export control compliance protocols and procedures are available online at: Export Control | Office of the Vice President for Research
POLICY HISTORY
Policy created: 12/14/2014 (Approved by the Vice President for Research)
Revisions:
1/12/2016 (Approved and Adopted by the UConn Health Policy Committee)
7/3/2018 (Non-Substantive edits per the Office of General Counsel)
9/18/2018 (Non-Substantive edits per the Office of General Counsel)
11/17/2025 (Approved by the Senior Policy Council and President)