The Harvard T.H. Chan School of Public Health is committed to openness of research and freedom of access and dissemination of information for the advancement of scientific discovery. The School is also committed to complying with all applicable laws and regulations, including those governing exports.
The Departments of Commerce, State, and Treasury administer the primary controls on exports of goods, commodities, and information. The Department of Commerce regulates the export of items and information that have civil applications, the Department of State regulates the export of items that have military applications or that relate to space, and the Department of the Treasury enforces country-specific embargoes and financial sanctions on individuals, organizations and countries. In certain circumstances, these agencies may require the University to secure a license before any items or information is exported to another country or shared with a foreign national. See the Harvard Export Control Policy Statement.
What kinds of activities might trigger export control issues?
In general, the shipment or transmission of items subject to the export control laws out of the United States or the release of technology or software (including source code) to a foreign national, whether in or outside the United States, is considered to be an export under the laws. Much of the controlled technology to which foreign nationals have access on campus at Harvard will not require licensing because of the exceptions in the regulations for “fundamental research” or “educational information.” These exceptions apply only to exchanges that occur in the United States.
Activities that might trigger licensing requirements are:
- International research collaborations;
- International shipments of certain viruses, equipment, software, or technology;
- Overseas travel, including conferences;
- The provision of financial assistance to an embargoed country or person or entity that is considered a blocked or sanctioned party
- The provision of professional services to a person or entity that is a blocked or sanctioned party or individual from an embargoed country.