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Overview for Faculty

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 Directorate of Defense Trade Controls (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).

Shipments: We recommend that new faculty members work with their Research Safety office, if applicable, and NU’s Research Safety office to successfully ship biological agents, pathogens, chemicals or other hazardous items. If you need to ship or travel with research items outside the U.S. while at Northwestern, please coordinate with our team (exportcontrols@northwestern.edu). We especially recommend that the following categories of shipments or hand carried items be reviewed by the ECIC office:

  1. High Risk Countries: Shipments to high-risk countries of concern (OFAC and Military End Use countries)
  2. Biologics or hazardous materials: Biologics or hazardous materials regardless of country
  3. Critical Technologies: All shipments for critical technologies regardless of country

Purchasing and Equipment: There may be export control considerations when purchasing and using certain items (equipment, materials, etc.). How will you know if an item needs a license or is highly controlled? Procurement flags indicating that authorization may be required are:

  • End-use or export control statements or agreements from the seller or manufacturer.
  • Purchase order with strong export control language.
  • EAR or ITAR-controlled markings.
  • The vendor notes shipping or foreign person restrictions.

Malign Talent Recruitment Program Prohibition: The U.S. federal government has ongoing concerns about Improper Foreign Influence and Malign Foreign Talent Recruitment Programs with respect to research. What does this mean for Northwestern researchers and personnel?

Research Visitors: Northwestern may not engage in transactions with a restricted party without prior government approval and will not sponsor research visitors from an entity on a US Restricted List. While we are committed to an open academic and research environment, it is essential to screen research collaborators and visitors to comply with federal regulations.

  • Restricted Party Screenings: All research visitors and visiting interns and volunteers require screening before Northwestern sends an appointment letter to the Visitor confirming offer and terms.
  • Can I host visitors affiliated/associated with a restricted entity? Northwestern will not routinely sponsor research visitors from an entity on a US Restricted List. There is a limited waiver/appeal process for certain instances. Please review the VPR’s April 15, 2025 memo regarding this policy. 

Research Security Training: Research Security training has been mandated by the government. This mandate stems from President Trump’s National Security Presidential Memo-33 (2021) and the CHIPs and Science Act (2022). Over the next year, each federal agency will implement this requirement, with the Department of Energy (DOE) leading the way. Starting May 1, 2025, covered and key personnel on DOE proposals (and potentially any listed researcher when applying for a specific notice of funding opportunity) must complete the training prior to submission, and researchers on existing DOE awards also need to complete the training. Northwestern’s Research Security team has created a one-hour NU training. Access the Northwestern Research Security Training here.

International Travel: Faculty traveling to OFAC-sanctioned countries for work/research purposes should register their official travel on the Office of Global Safety and Security’s International Travel Registry. If you are traveling to a Military End Use country, there are also export control considerations. Please visit the ECIC International Travel website for further information.

Questions for Faculty – IF YES to any of the below, reach out to the ECIC team at exportcontrols@northwestern.edu for assistance and guidance.

__ Do you have any export-controlled projects or are any of your projects on a Technology Control Plan?

__ Are any of your projects military or space related?

__ Do you have any awards or agreements with publication approvals, where you cannot openly publish?

__ Do you have any awards or agreements with foreign person restrictions?

__ Do you receive funding from an international source?

__ Do you have any international collaborators from designated foreign countries of concern (China, Iran, North Korea or Russia)?

__ Do you anticipate working with individuals located in OFAC sanctioned or Military End Use countries?

__ Do you have any questions for the ECIC team?

List of OFAC Sanctioned Countries and Military End Use Countries:

OFAC Sanctioned Countries: These countries change over time but are currently Belarus, Cuba, Iran, North Korea, Russia, Syria, and certain regions of Ukraine (Crimea, Donetsk, Luhansk, and Sevastopol).

Military End-Use Countries: These countries change over time (currently Belarus, Burma, Cambodia, China, Iraq, Nicaragua, Russia, Venezuela). There are also restrictions for several countries if the collaborator or intended recipient is affiliated with a military end-user or is a military end-use entity. As a result, collaborations or shipments, including material transfer agreements, tech transfer activities, licensing agreements, and joint ventures with these countries require review.