This guidance provides faculty with essential information on when and how U.S. export control regulations may impact your research, collaborations or international activities, and guidance on what to do if your project involves controlled technologies or restricted parties.
Export control review and determination
An export control review is the process of evaluating research projects, international activities or transactions to determine whether they involve technologies, data or collaborations subject to U.S. export control regulations.
An export control review may be necessary when your research or professional activities involve:
- Collaborations with foreign institutions, companies or individuals.
- Use of specialized equipment, software or technical data with potential military or dual-use applications.
- Restrictions on publication or foreign national participation in sponsored research.
- International travel with research materials, devices or proprietary data.
- International shipments of research-related items.
If any of these situations apply, contact USC’s Export Control Officer to request a review.
Faculty are encouraged to reach out to the Export Control Officer:
- At the proposal or planning stage of a new project
- Before sharing technical data with international collaborators or students
- Before hosting foreign visitors on research teams
- Before traveling abroad with research devices or data
- Before shipping research materials internationally
- If your sponsor agreement includes publication, access, or nationality restrictions
Early consultation helps ensure compliance and protects your research from delays or penalties.
If your research or activity falls under export control regulations, the USC Export Control Officer will assist with:
- Development of a Technology Control Plan (TCP): USC’s Export Control Officer will help you develop a documented compliance strategy that outlines how controlled information, materials or equipment will be secured. It includes physical and electronic access controls, data handling procedures and training requirements.
- Personnel Discussions: You will work with the Export Control Officer to determine which personnel can legally access the project and whether participation by foreign nationals will require license authorization or exclusion. This may affect hiring, student involvement or visiting scholar access.
- License Determinations: The Export Control Officer will evaluate whether an export license is required based on the project’s scope, the nationality of participants, the destination of exports, and the nature of the data or technology involved.
- Applying for a License: If needed, the university will work with the USC faculty or personnel to submit a license application to the relevant federal agency (e.g., the Departments of Commerce, State or Treasury). The review process can take weeks or months, so early notification is essential.
- Managing the Daily Operations of an Export-Controlled Project: Once active, export-controlled projects require ongoing compliance, including:
- Adhering to the TCP.
- Restricting access to approved personnel.
- Keeping detailed records of project activity and access.
- Reporting changes in scope, personnel or international interactions.
International Jobs or Activities During Summer or Sabbatical Leave
Faculty planning to conduct research, teach, consult or collaborate abroad during summer or sabbatical leave must consider export control implications, especially if:
- The work involves controlled technologies or technical data.
- The destination is a sanctioned or restricted country.
- The foreign host institution or employer is on a denied party list.
- There is potential for sharing non-public or proprietary research.
Before confirming international commitments, contact the USC Export Control Officer to:
- Assess whether an export license is needed.
- Determine if your activity qualifies for a regulatory exemption.
- Ensure you avoid restricted collaborations or travel violations.
It is also recommended to reach out to the Office of Research Security prior to committing to international jobs or activities during the summer or while on sabbatical leave.
Questions?
If you're unsure whether your activity is export controlled, it's always better to ask early. Contact the USC Export Control Officer for confidential support, review and guidance.