University Policy Manual

Export Control Policy

Policy Category Issuing Authority Responsibility Publication Date Next Review Date
Risk Management & Security President Office for Research and Innovation 7/11/2025 7/11/2028

 

Policy Statement & Background:

United States federal export control laws and regulations ("export control laws") exist to protect U.S. national security and foreign policy interests. Export control laws restrict certain types of items, software, technology and technical data (information) from being sent (through any means) to certain individuals, entities, or countries, including to U.S. citizens, or from being made available to foreign persons within the U.S. Several U.S. agencies have regulatory authority over exports, including but not limited to the: Department of Commerce (Export Administration Regulations), Department of State (International Traffic in Arms Regulations), and Department of Treasury (U.S. economic sanctions programs).

 

The penalties for violating export control laws can be significant and may result in criminal sanctions and/or fines against the individual and/or the University, loss of exporting privileges for the University, and/or loss of federal funds.

 

Policy:

All members of the Campus Community must comply with U.S. export control laws when conducting any activity (1) on University controlled premises, or (2) on behalf of the University at any domestic location, or (3) on behalf of the University in a foreign country. Stony Brook University's Office for Research and Innovation shall develop and implement this policy and the University's export compliance program. Members of the Campus Community must report suspected or actual export control violations to the Director of Research Security (see Reporting section below).

 

Objective

The goal of the University's export compliance program is to facilitate compliance with U.S. export control laws, while balancing the University's commitment to openness in research and education.

 

Training

The Office for Research and Innovation provides a variety of training materials to support the Campus Community with export control laws compliance. Campus training resources, government training resources and other resources are available on the University's Export Controls website.

 

Responsible Parties

 

Campus Community: All members of the Campus Community must understand the export control law requirements, if and/or how they apply to their University responsibilities and/or research activities, and to practice due diligence to ensure compliance. No member of the campus community may partake in any action(s) prohibited by the export control laws. No member of the campus community may transfer any controlled information, technology or commodity without the proper University authorization.

 

Director of Research Security (DRS): The Director of Research Security serves as the Vice President for Research and Innovation’s (VPRI) designee for the University Research Security Program inclusive of the University’s export compliance program.

 

Empowered Official (EO): The Vice President for Research and Innovation (VPRI) and the Director of Research Security serve as the Empowered Officials for the International Traffic in Arms Regulations. The VPRI may appoint additional EOs if deemed appropriate.

 

Export Compliance Officer (ECO): The University official responsible for the University's export compliance program. The ECO assists academic and administrative offices in the development of policies and guidance documents to ensure compliance with the export control laws and this policy.

 

Research Security Working Group (RSWG): A committee chaired by the Director of Research Security that includes members of administrative offices that have some responsibility in export compliance. The RSWG assists in the evaluation and maintenance of the University’s posture for compliance with federal government export control regulations.

 

Vice President for Research and Innovation (VPRI): The VPRI is the authorized University official for the University's export control program. Technology control plans, commodity jurisdiction requests, export license applications, and any other request to a federal agency regarding export controls, as well as any requests for publication and/or foreign national waivers, must be authorized by the VPRI or his/her designee.

 

Procedures & Guidance

As part of the University's export compliance program, a number of guidance and procedure documents are in place to educate the Campus Community and support compliance. The Campus Community is required to adhere to these items, which are available on the University's Export Controls Website.

 

People

  • Restricted Party Screen - Who Should be Screened
  • How to Conduct a Restricted Party Screening
  • Foreign Person Employee Guidance
  • International Collaborations Guidance
  • International Visitor Guidance

 

Places

  • Conferences, Events & Seminars - Hosting, Attending or Presenting Guidelines
  • Electronic Communications Guidance
  • Filming on Campus
  • International Shipment and Transfer Guidance
  • Shipper Self-Assessment Review Procedure
  • International Travel Guidance

 

Things

  • Classification of Item/Information Procedure
  • Purchase of Goods Guidance
  • Software and Encryption Guidance
  • Other than Tools of the Trade Self-Assessment Review Procedure
  • Tools of the Trade

 

Recordkeeping

The University is required under the export control laws to maintain all records for a period of five (5) years from the date of the transaction (i.e. research project, shipment, academic travel, host a foreign visitor).

 

Reporting & Investigation 

Members of the Campus Community must report suspected or actual export violations to the Director of Research Security (ideally within 24 hours after becoming aware of a potential or actual violation). Reports may be submitted by either:

  • EthicsPoint: Reports may be submitted via the University’s secure third-party confidential reporting system by web and mobile devices or telephone (see information provided below). Select the “Export Control/Research Security Concern" type. Reports may be submitted anonymously.
  • Telephone: Reports may be made directly to the University at (631) 632-1954.

 

The Director of Research Security will promptly notify the Vice President of Research and the Office of General Counsel, and investigate all reports. When necessary and feasible, the University may issue an official direction to cease a transaction or activity, pending the completion of its review.

 

Contact by a Government Agency

If a government agency contacts you directly regarding a suspected or actual export control violation, immediately report such contact to the Director of Research Security (see contact information below) and await further instructions.

 

Compliance

Noncompliance with this policy may result in:

  • The University imposing disciplinary and/or legal action on the individual; and/or
  • Federal agencies imposing fines, sanctions, and possible jail time on the individual.

 

Definitions:

Activity: research, education, service or business purpose.

 

Campus Community: in this policy, the term Campus Community includes but is not limited to all faculty (including voluntary, lecturers, and adjuncts); research personnel (including research staff, post-doctoral fellows, research associates); visiting scientists and scholars, graduate and undergraduate students involved in research activities; visiting scholars, consultants or other volunteers involved in research activities; non-research staff in departments, centers, institutes, colleges, administrative offices that are involved with transactions covered under this policy.

 

University: in this policy, the term University includes all schools, centers, institutes, and administrative offices within the State University of New York at Stony Brook, the Research Foundation for State University of New York as it relates to Stony Brook University, Stony Brook Medicine (including University Hospital), and the Long Island State Veterans Home.

 

Contact:

Additional information about this policy is available here:

Office for Research and Innovation

S5424, Frank Melville Jr. Memorial Library 

Stony Brook, NY 11794

(631) 632-7932
https://research.stonybrook.edu/offices

 

Susan Gasparo

Director of Research Security

Export Compliance Officer
(631) 632-1954
Susan.Gasparo@stonybrook.edu

 

Relevant Standards, Codes, Rules, Regulations, Statutes and Policies:*

 

 

*Other Applicable Regulatory Agencies: additional regulations may also apply from

  the: Department of Energy, Nuclear Regulatory Commission, Environmental Protection  

  Agency, Center for Disease Control, Food and Drug Administration, and Drug

  Enforcement Agency.