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Northwestern Qatar (NU-Q)

All Northwestern activities in the Northwestern Qatar Campus (NU-Q) are subject to U.S. export controls, OFAC, and research security regulations. 

Overview: The Export Controls & International Compliance (ECIC) team helps faculty, staff, and students navigate export control and other international compliance regulations (i.e., foreign interference and malign foreign talent programs).  Northwestern is a fundamental research university, meaning that we do not accept projects with publication approvals or certain foreign person restrictions due to our openness in research (Reference: Export Control Policy). By not accepting these restrictions, we are able to use the fundamental research exclusion (FRE) for most, but not all, licensing requirements. For example, international shipments are not covered under the FRE.

Northwestern is not registered with the State Department DDTC, to handle/store/work with ITAR projects. The International Traffic in Arms Regulations (ITAR) are the United States regulations that control the manufacture, sale, and distribution of defense and space-related articles and services as defined in the United States Munitions List (USML).

1. Is NU-Q a ‘U.S. person’ under export and OFAC regulations? Yes, all U.S. incorporated entities and their foreign branches are subject to OFAC regulations and a “US person” under the EAR.  See OFAC FAQ, ITSR  560.314, 560.215, EAR 15 CFR 772.1. 
2. Are ‘U.S. persons’ living in Qatar and working for NU-Q subject to U.S. export control regulations (EAR/ITAR/OFAC)? Yes, both U.S. and non-U.S. persons must comply with export control regulations under the EAR and ITAR, and with OFAC sanctions regulations, including all U.S. citizens and permanent residents regardless of where they are located. See OFAC FAQ. 
  • Example: A NU-Q faculty member—regardless of U.S. person status—wants to host a visitor who is ordinarily a resident of an OFAC-sanctioned country. The faculty member will need to reach out to the ECIC office to conduct a restricted party screening and for a licensing determination.
  • Example: A PhD student in NU-Q wants to ship or travel with a camera and other filming equipment to China – a military end use country. The student will need to contact the ECIC team to conduct a restricted party screening and for a licensing determination before traveling or shipping the equipment.
3. Why do U.S. regulations apply to non-U.S. persons at NU-Q? Non-U.S. persons working for NU-Q (faculty, staff, post-docs) or enrolled in a NU-Q program are affiliated to a U.S. person and therefore activities performed by virtue of this affiliation will require compliance with U.S. export control regulations.
4. How do research security requirements apply to NU-Q? Research security requirements by federal agencies are triggered when researchers at Northwestern, including at NU-Q, apply or receive U.S. federal funding, regardless of their U.S. person status or location. It is essential for Northwestern researchers receiving federal funding to complete and update federal agency and Northwestern disclosures. Visit our Research Security website for guidance and resources.
5. Does NU-Q require a specific OFAC license to provide educational services to individuals who are ordinarily a resident of comprehensively OFAC-sanctioned countries but physically in Qatar to take coursework? The Iranian Transactions Sanctions Regulations authorize U.S. academic institutions with undergraduate educational programs abroad to educate students who are ordinarily residents in Iran, as long as the course is in the humanities, social sciences, law, and business at the undergraduate level (31 CFR 560.544).
6. Does NU-Q require a specific OFAC license to provide online educational services? There are OFAC restrictions related to taking online courses abroad. Licenses to provide a service to sanctioned countries are required under some circumstances. There may also be license requirements for software and other items. See applicable license requirements for each country in our Online Coursework in Sanctioned Countries guidance and the FAQs on OFAC Online Courses for additional information.