Drexel University engages in research, scholarly, and creative activities that involve the development or use of products, goods, hardware, software, materials, information, or technology. Such activities may be subject to U.S. export control laws and regulations (Export Controls).
Export Controls are pimarily implemented through the following three regulatory regimes
- U.S. Department of Commerce (Commerce)
Export Administration Regulations (EAR) (Title 15 CFT 700-799)
Regulations governing hardware, materials, equipment, software, technology and technical data that Commerce defines as dual use i.e., having commercial and inherent military or proliferation application. Commerce enforces destination (country) and end user/use-based controls by requiring authorization (license) for controlled items prior to export. Controlled items are listed on the Commerce Control List (CCL) under an Export Control Classification Number (ECCN). Whether or not a license is required is a determination based on ECCN, any applicable license exclusion, country of destination and ultimate end user/use.
- U.S. Department of State (State)
Internal Traffic in Arms Regulations (ITAR) (Title 22 CFR 120-129)
Regulations governing defense articles and defense services, where defense articles are defined generally as hardware, materials, equipment, software, technology and technical data, specifically designed or modified for defense or military application without a civil performance or use equivalent. Unlike the EAR's dual-use universe, exports of ITAR items are subject to licensing regardless of destination or end user/use, unless a specific license exception is met. ITAR-controlled items are listed on the US Munitions List (USML).
- U.S. Department of the Treasury (Treasury)
Office of Foreign Assets Control (OFAC) (Title 31 CFR 500-598)
Treasury’s economic embargo controls governing restrictions on transactions to certain OFAC-defined terrorist-sponsoring nations. Similar to the EAR and ITAR, transactions with these countries may require licenses.
Drexel is committed to the highest level of compliance with all relevant federal export controls regulations. Since severe criminal and civil penalties may arise from non-compliance with the federal export control regulations, it is critical for everyone in the Drexel community to understand their responsibilities and stay fully compliant. Thus, Drexel has created Export Compliance content on the OR website to provide pertinent information to keep the community informed.
Drexel Export Control Compliance Policy Statement [PDF]
Drexel's Export Control Handbook [PDF]
If, after consulting the materials provided on this OR website, you have any questions, comments, or concerns, please contact Export Compliance (firstname.lastname@example.org).