Policy and Regulations

Institutional Policy

GW’s Export Control Policy explains how the university implements export control laws that advance national security and economic interests. It provides important information that enables the GW community to understand export control regulations and the procedures designed to ensure university compliance.

Although many university activities are exempt from export control laws and regulations, some activities may fall under the regulations. Members of the university community must understand their obligations under U.S. export controls and promote compliance within these regulations. Failure to comply with these laws exposes faculty, staff and students as well as the university to severe criminal and civil penalties including fines and prison sentences as well as administrative sanctions (i.e. loss of research funding and export privileges.

International Traffic in Arms Regulations (ITAR) 22 C.F.R. Parts 120-130	Export Administration Regulations (EAR) 22 C.F.R. Parts 120-130	Office of Foreign Assets Control (OFAC) 31 C.F.R. Parts 500-599
Administered by the U.S. State Department's Directorate of Defense Trade Controls (DDTC), ITAR regulates the export and temporary import of defense articles (i.e., items that are inherently military in nature and/or are classified) and defense services on the U.S. Munitions List (USML). ITAR defense articles include all items, software and technical data set forth on the USML as well as any item that was specifically designed, developed, configured, adapted or modified for a military application or have an inherent military nature and does not have predominant civil application. Commercial items can also become subject to ITAR if specially modified for a military application.	Administered by the Commerce Department's Bureau of Industry and Security (BIS), these regulations apply principally to goods, software and technology that have both potential commercial and military applications known as "dual-use" items. These items are not subject to the ITAR and are categorized on the Commerce Control List (CCL). Like ITAR, EAR governs both exports of goods, software and technology from the U.S. as well as deemed exports of technology and software source code to a foreign person in the U.S.	A branch of the Treasury Department, OFAC administers U.S. embargo and sanctions programs. These regulations apply to designated countries, entities, and individuals. The sanctions programs vary in nature (e.g., territorial or "list-based") and scope (e.g., comprehensive or limited) and may restrict a broad range of exports, imports, and other transactions, including providing educational or research services. View a current list of OFAC sanctions programs.
Additional Resources Directorate of Defense Trade Controls: Frequently Asked Questions	Additional Resources Export Administration Regulations (EAR) This database maintained by the Bureau of Industry and Security, Department of Commerce, is a complete collection of regulations relating to EAR. Supplement 1 of 15 CFR Section 774 is represented by Categories 0-9. Deemed Export Presentation Export Control Decision Map: “Is My Activity Subject to the EAR?” Determination Chart”	Additional Resources OFAC Country Sanctions Programs OFAC FAQ Boycotted Countries: Treasury Dept. Office of Foreign Asset Control (OFAC)

Other U.S. federal agencies that oversee export control agencies include: