- Basics & Regulations
- Campus Activities
- Common Definitions and Terms
- Embargo & Sanction Programs
- Export Control Regulations
- Government Information
- Training & Resources
- Controlled Unclassified Information
- Export Controls
"FUNDAMENTAL RESEARCH means basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community (as distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons). READ MORE
PROPRIETARY RESEARCH means research and industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons (as distinguished from fundamental research- basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community). READ MORE
No, Information resulting from Fundamental Research is not subject to the export regulations.
Remember: third-party proprietary information - even if used for a fundamental research project - is subject to the export regulations and may need an export license to share with a foreign national (even a SBU employee),
Third-party proprietary information is information from another source that is not in the public domain. Third-party proprietary information is subject to the export regulations. READ MORE.
Yes, the Fundamental Research Exclusion pertains to the INFORMATION resulting from fundamental research project. It does not pertain to the tangible products (e.g. materials, prototypes, equipment, software) resulting from the fundamental research projects.
A restricted party (or denied party as they are sometimes referred to) is an entity or individual that is placed on a denial list by the U.S. government or any other country’s government. A license from one, or more, of the federal agencies may be required if you plan on conducting any business or research with a restricted party, even if you are conducting Fundamental Research. READ MORE
The export regulations include categories of information that are considered "publicly available" (available to the public without any restrictions). Publicly available information is not subject to the export regulations (e.g. ITAR, EAR), however - it can be prohibited to send publicly available information to an embargoed/sanctioned country without a license. READ MORE
Embargo is a ban on trade for all transactions without a license whereas a sanction a prohibition on certain exports or activities without a license. Depending upon the sanction program restrictions may include: financial transactions, provision of services, shipment of particular items, travel, sharing of information that is not in the public domain. READ MORE about Embargo/Sanction Programs
A voluntary disclosure is notification to a federal agency that an export violation may have or has occurred. If it is found that an export violation did occur, a voluntary disclosure will be seen as a mitigating factor (in most cases) when determining penalties and/or sanctions. If after reviewing the information provided on this website or any other export compliance resources and it is believed that an export violation may have occurred, please contact the Office of Research Compliance or use the University's Confidential Export Control Escalation Process. READ MORE
Before sharing information with collaborators, whether in the U.S. or abroad, determine if the information is publicly available - if not an export license may be required to share the information.
SUNY Policies PROHIBIT the acceptance of any awards that:
- Requests for justifiable exceptions to this policy, on a case-by-case basis, such as for the purpose of protecting state and national security, must be submitted to the Office of Research Compliance for submission for Chancellor or designee authority’s approval.
- Any projects that are granted exceptions to these SUNY policies will be further reviewed for the need of a Technology Control Plan and/or export licenses.
A license or documented license exception is required for foreign persons to use ITAR controlled items and/or technical data. READ MORE
- Embargoes and Sanctions
Yes, a specific license is required from the Office of Foreign Asset Controls (OFAC) to attend a conference in Iran. READ MORE
The Office of Foreign Asset Controls (OFAC) has a general license for specific types of programs, programs outside of these specifications require a specific license. READ MORE
Contact the export compliance officer before engaging in an activity with a person in an embargoed or sanctioned country.
In September 2020, the Office of Foreign Asset Controls (OFAC) removed from the general license authorization for persons subject to U.S. jurisdiction to (1) attend or organize professional meetings or conferences in Cuba and (2) participate in or organize certain public performances, clinics, workshops, other athletic or non-athletic competitions, and exhibitions. These activities now require specific licenses.
No, all travel to Cuba requires either a general license or a specific license. All travel to Cuba should be reviewed by the export compliance officer prior to travel. This review will confirm that travel is being conducted under the correct license type.
Yes, travel to Iran is allowed. However, a general license or a specific license is required for most research and educational activities. All activities to take place in Iran should be reviewed by the export compliance officer prior to engaging in the activity. This review will confirm that the activity is being conducted under the correct license type.