Can a student at a university listed on the Entity List intern at my company?
A student’s enrollment at a university included on the Entity List is a “red flag” which requires exporters undertake an additional level of due diligence before proceeding with any such transaction. However, a student is not an integral part of the university (e.g., does not have fiduciary duty to from the university in the same manner that as an employee, officer, trustee or person in a similar position in the university would) in which he/she is enrolled and therefore BIS does not include them in the licensing requirements and policy specific to the university. With the caveat of the red flag mentioned above, BIS advises exporters to treat exports, reexports and transfers (in country) to students as shipments to the country of which the student is a citizen.
