Receiving or Using Export Controlled Items
Overview
University of Utah employees who receive or use export-controlled items, equipment, software, biologics, or technical data must follow strict procedures to ensure compliance with U.S. export control laws and university policy.
Why It Matters
Export-controlled items are subject to federal regulations such as the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and Office of Foreign Assets Control (OFAC) sanctions. These rules govern how sensitive technologies and information can be shared, stored, and accessed—especially when foreign nationals are involved.
If you anticipate receiving controlled items—whether physical or digital—you must:
- Notify the Research Security Office (RSO) in advance.
- Provide details including:
- Source and country of origin
- Description and purpose of the item
- Intended location of use or storage
- Any related agreements (e.g., MTA, NDA)
The RSO will:
- Conduct a compliance review to determine applicable regulations
- Screen the source against federal restricted party lists
- Assess licensing needs and any limitations on use, sharing, or publication
- Classify risk level and coordinate with General Counsel, EH&S, or other offices as needed
If the item is deemed moderate or high risk, a Technology Control Plan (TCP) may be required to manage access and security.
- Complete required training on export control compliance
- Implement safeguards such as secure storage, access restrictions, or monitoring
- Maintain documentation of receipt, use, and any transfers
- Notify the RSO of any changes in use, disposal, or transfer of the item
The RSO works closely with the Office of Sponsored Projects (OSP) and the Technology Licensing Office (TLO) to ensure all agreements and transfers are reviewed appropriately. If you're unsure whether an item is export-controlled, contact us before accepting or using it.