Export Controls & Sanctions Compliance

Most international collaborations and exchanges are permissible as a general matter, but the involvement of restricted recipients or certain sensitive technologies or materials can trigger federal regulatory requirements intended to protect US foreign policy and national security interests.

The University’s Export Controls Office is responsible for systemwide compliance with these requirements, provides guidance on request, and will apply for federal authorization when needed.

Export Controls

Export controls such as the Export Administration Regulations and International Traffic in Arms Regulations require government authorization for certain exports of:

  • Tangible items and non-public technologies to restricted countries, businesses, governments, universities, and individuals
  • Sensitive and controlled commodities, technologies, and software

Federal authorization is more likely to be required when the receiving location or entity is subject to special restrictions (e.g., Cuba, Iran, Huawei Technologies, National University of Defense Technology, among others) or when the items in question are sensitive or dangerous, such as thermal imaging gear or certain pathogenic microorganisms.

When sending tangible research materials to parties outside the US, personnel must ensure that a material transfer agreement (MTA) is in place. To request an MTA, please complete an MTA Request Form and email it to otcagree@umn.edu. The ECO conducts export compliance reviews of all MTA requests involving non-US recipients.

Trade Sanctions

The Foreign Assets Control Regulations impose a variety of restrictions on the international movement of money, services, goods, and sometimes even people. Collaborations or travel involving specially sanctioned entities or embargoed countries must have ECO approval. As of August 2021, the comprehensively embargoed countries are:

  • Cuba
  • Iran
  • North Korea
  • Syria
  • Ukraine (Crimea, Donetsk, and Luhansk regions only)

Key University Policies