Collaboration with Russian, Belarusian, or Ukrainian entities remains at high risk. Please contact the CU Office of Export Controls prior to any new or continued engagement.
The U.S. government continues to expand sanctions and export controls to address the Russian aggression and invasion of Ukraine, causing the regulatory topography to evolve on a weekly basis. The recent identification of 120 Russian or Belarusian "denied" entities in certain areas of science and technology, including various research institutes, highlights the expansion of U.S. sanctions beyond just governmental organizations or individuals connected to the government. It also emphacizes the need for careful review of any interaction in those areas. OEC will continue to provide updates and guidance here. Please check this site frequently and reach out if you have specific questions.
U.S. laws on export controls and economic sanctions shape the way in which university researchers can engage with foreign nationals, both in the United States and abroad. In general, these regulations focus on equipment, materials, software and technology that have either a direct military application, or fall into a larger group of “dual-use” items (where there are both civil and potential military uses). There are many areas of research at CU Boulder that can potentially implicate export controls, including space-focussed technologies, lasers and other lab equipment, and select agents and biological toxins. In addition, CU's financial transactions with individuals in certain embargoed countries, including paying researchers or providing online education, create an additional layer of risks to assess and compliance to ensure.
Notably to activities on campus, export controls are not limited to the physical export of equipment or software. "Deemed exports” include dissemination of technical information to foreign persons, whether it occurs within or outside the US. This may occur in the context of presentations, emails, personal conversations, site tours, or in training of foreign national research personnel. Penalties for violations can be severe and accrue to individual investigators as well as the University, so it is important for investigators and administrators to be aware of their responsibilities.
Much of the research accomplished at CU is basic and applied science and thus not subject to export controls. However, the university is growing its portfolio of restricted research, and the federal laws on the topic are changing rapidly. In some cases, it may be necessary to apply for an export license, or to create a Technical Assistance Agreement, to identify, seek approval, and limit the scope of a foreign engagement. Licenses and TAAs can take considerable time to develop, so PIs should contact the Office of Export Controls as early as possible if you think these may be required.
The empowered official for the Boulder campus at the moment is the primary contact for more information about export control regulations:
- Erik Lowe JD, LL.M
Director, Office of Export Controls