What is an export?
Any oral, written, electronic or visual disclosure, shipment, transfer or transmission outside of the United States to anyone, including a U.S. citizen, of any commodity, technology (information, technical data, or assistance) or software/codes. Such exports include transfers of such items or information to foreign embassies, overseas corporate affiliates, and contractors.
What is a deemed export?
Any oral, written, electronic or visual disclosure, transfer or transmission to any person or entity of a controlled commodity, technology or software/codes to a non-U.S. entity or individual, wherever located (even to a foreign student or colleague at Northwestern University)
Who is a foreign national?
A Foreign National is an individual who is not a United States citizen, a permanent resident alien of the United States, a lawfully-admitted temporary resident alien or refugee, or other protected individual as defined by 8 U.S.C. 1324b(a)(3). For purposes of Export Controls, individuals on a student visa or H1 visa (including foreign visiting faculty) are considered Foreign Nationals.
Countries subject to sanction
While exports to all countries are controlled in various ways, there are very strict prohibitions on shipments and interactions with the following countries currently considered by the U.S. Department of State to be state sponsors of terrorism, known to have to have repeatedly provided support for acts of international terrorism: Cuba, Iran, Sudan, and Syria. Additional countries under sanction are identified on both the Department of Treasury and the Department of Commerce websites.