Do export controls apply to research activities?
When U.S. universities undertake basic or applied research on campus in the United States, the results of which will ordinarily be published (and which are not treated as proprietary), the research results may be excluded from certain export control provisions. This exclusion may apply to collaborations with researchers from other countries when the research is conducted in the United States. However, research conducted with non-U.S. collaborators outside the United States may require a license prior to undertaking the activity, including transfer of information sufficient to develop research proposals. A “deemed export” may occur in research conducted within the United States if a visiting scholar or foreign student participates and the research is not covered by the fundamental research exclusion. An export license must be obtained prior to any deemed export.