Teaching and Export Controls

Is the Course you Teach or Plan to Teach Subject to Export Controls?

At the UPRM we do not have international subcampuses, MOOCs or virtual programs. Export or import educational service from a sanctioned or embargoed country may be prohibited or required a license. The Office of Foreign Assets Control (OFAC) has issued some license exceptions, as in the case of Iran, which allows Iranian students to take online undergraduate level courses from US Universities in the humanities, social sciences, law, or business, as well as introductory undergraduate level science, technology, engineering or math courses which are required for the completion of a degree program in the humanities, social sciences, law, or business.

Academic administrators only have to evaluate whether courses with advanced or sensitive technology qualifies for the educational exclusion. First determine which export control regulations has jurisdiction over the course’s technology, and second, evaluate if the course qualifies for the educational exclusion.

• Export Administration Regulations (EAR), administered by the U.S. Department of Commerce, provides that educational information released by instruction in catalog courses and associated teaching laboratories of academic institutions (with some encryption exceptions) is not subject to the EAR [EAR §734.3(b)(3)(iii) ]. The EAR education exclusion does not extend to the release of information in research labs not associated with catalog courses.
• International Traffic in Arms Regulations (ITAR), administered by the U.S. Department of State, provides that information concerning general scientific, mathematical or engineering principles commonly taught in schools, colleges and universities, is not included in the definition of technical data subject to the ITAR [§120.10(a)(5)].

If the course regarding an advanced or sensitve technology that do not qualifies for the educational exclusion, then it must be evaluated to include the required disclosure and participation.

If you plan to create an open virtual course or an advanced or sensitive technology graduate course, please contact Héctor Segarra, Export Control Officer, Research and Development Center, at extension 5344 and via e-mail at exportcontrols@uprm.edu.