Compliance

Visa Deemed Export Certification

Background

The U.S. Citizenship and Immigration Services (USCIS) recently issued a new form I-I29 that requires a change in procedures when the University hires a foreign person as faculty and staff. A key change to the form is the inclusion of a “Deemed Export Attestation,” which requires the petitioner (i.e. the University) to certify whether visa petitions for certain classes of foreign person work visas will require a license or other government authorization for the...

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Glossary

Code of Federal Regulations (CFR) — The United States Code of Federal Regulations (CFR) is the codification of the general and permanent rules and regulations published in the Federal Register by the executive departments and agencies of the Federal Government.

Commerce Control List (CCL) – A list of items under the export control jurisdiction of the Bureau of Industry and Security, U.S. Department of Commerce. The CCL is found in Supplement 1 to part 774 of the EAR.

Commerce Control List (CCL) Category – The CCL is divided into...

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Exclusions

If you have any questions on whether your research, travel, collaborations or export of any goods and services are subject to export controls or meet the exclusions listed below, please contact Jennifer Neira, our School's Export Control Administrator.

Fundamental Research

For the purposes of export control regulations, the term Fundamental Research means:

Basic...

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Regulations

Harvard Policy

Harvard University is fully committed to compliance with applicable U.S. laws and regulations pertaining to exports of items, services and technology by or on behalf of Harvard.  ...

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International Collaborations

International Collaborations/On-Line Education and SDNs

In addition to countries, foreign individuals and entities may also be the subject of U.S. sanctions.  These individuals/entities are considered Specially Designated Nationals ("SDNs"). 

  • Before traveling to countries that may be the subject of sanctions, collaborating with a foreign national outside of Harvard University or any person or entity outside of the United States, or presenting your research at an international conference,...

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Foreign Travel Issues

Foreign travel raises a number of issues for researchers, as any trip outside the United States has the potential for the researcher to export both items and technical information that may be controlled.  For these reasons, it is recommended that you review Harvard’s Global Support Services travel tools page, and keep in mind a few simple points while traveling abroad:

  • Shipped v. Carried Items:  First, the export-control laws do...
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International Shipping

Research collaboration often involves the sharing of research materials, including biological samples, chemicals, reagents, research prototypes, and research equipment, including laptops to lasers.  The transport and exchange of research materials may be subject to strict regulatory requirements related to the health and safety of shipping carriers and the public, international sanctions, protection of intellectual property, and export controls.

The U.S. government actively regulates, and in some cases, restricts the export of certain items and information, including...

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Deemed Exports

Generally, any item (commodities, software or technology, technical information, blue prints, design plans, circuit boards, etc.) subject to the Export Administration Regulations (EAR) that is shipped or transmitted from the United States to a foreign destination is an export.  In addition, technology, know how, and non-encryption source code that is released to foreign national within the U.S. is “deemed” to be an export to the country where the person is a resident or citizen and could be subject to licensing requirements.  This is what is commonly known as the “...

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