General Prohibitions
Under U.S. export controls and sanctions laws, these activities always require federal government authorization. Therefore, you must contact ORIA before engaging in any of these activities.
- Any Involvement with Proscribed Persons or Entities
You must obtain federal government authorization before involving yourself with a person or entity that is proscribed by the U.S. Government or whom you know is affiliated with or a member of a proscribed person or entity. Such involvement includes research collaboration and the procurement from/provision of equipment or other items. Proscribed persons and entities tend to be involved in criminal or WMD proliferation activities, and include certain foreign academic institutions, scientific institutions, and academics, especially in countries about which the U.S. government has significant foreign policy or national security concerns.
Therefore, please contact ORIA unless the recipient/end user is well known by you not to be proscribed (e.g., University of London, European Space Agency, etc.). We will check the recipient person/entity against the proscribed lists to ensure the transaction's legality. Cornell is in the process of acquiring a software program used by other major research universities, which quickly screens names of persons and entities against the proscribed lists.
- Activities Relating to the Proliferation of Weapons of Mass Destruction
You must obtain federal government authorization before engaging in any activity (
e.g., training, assistance, financing, contract performance, transference of
items,
information, or
software) where you
know or have reason to believe that the activity relates to nuclear explosive activities; chemical or biological weapons and precursors; maritime nuclear propulsion projects, plants, or facilities; nuclear activities; civilian or military rocket systems; missiles; or unmanned aerial vehicles of any size that fly for a range of 300km or more or are designed to carry chemical, biological, or nuclear weapons.
- Activities Involving Cuba, Iran, Sudan, Syria, North Korea, or Burma (Myanmar), or a National or Entity of one of these Countries, wherever located
Please call ORIA for information before traveling to one of these countries.
Moreover, scholarly activities involving or conducted for the benefit of an entity or a national of one of these countries (but not a permanent resident alien in the United States), wherever such entity or national is located, may require a license. Please call ORIA before engaging in any such activity. Here are
some examples.
Special Note on Peer Review
A December 17, 2004 OFAC General License allows most review/editing/joint authorship activities with nationals of Cuba, Iran, and Sudan, but not, however, with the governments or government employees of these countries. Almost all other services require an inquiry into license requirements. Of course, please call ORIA if you have any doubt as to whether your activity is export-controlled, or whether the person or entity with whom you are dealing qualifies as governmental.
- Provision of technical assistance to a non-U.S. person with respect to encryption
A license is required to provide technical assistance to non-U.S. persons with the intent to aid them in the development or manufacture of encryption commodities or
software outside the United States.
However, the mere teaching or discussion of information about cryptography, such as in an academic setting or in the work of bodies engaged in standards development is not export-controlled, even if non-U.S. persons are present.
- Furnishing Assistance to Non-U.S. Persons with respect to Military or Space-Related Items
Please contact ORIA before furnishing assistance (including training) to anyone other than a U.S. person located in the United States, in the design, development, engineering, manufacture, production, assembly, testing, repair, maintenance, modification, operation, demilitarization, destruction, processing or use of
- Military articles or articles related to military end uses, including components specifically designed or modified for such; or
- Satellites, other spacecraft, or other space-related technology, including components specifically designed or modified for such. (Please read about Space-Related Transfers of items, software and technical data)
