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?
A deemed export refers to the release of export-controlled technology, technical data or source code to any foreign national in the United States (even to a foreign student or colleague at Northwestern). Technology may be "released" for export by activities such as use of a controlled material, training on the use of controlled equipment, or dissemination of controlled research data and information by email or in conversations.
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 individuals as defined by 8 U.S.C. 1324b(a)(3). For purposes of Export Controls, individuals on a student visa or H1 visa (including visiting foreign faculty) are considered Foreign Nationals.
Countries subject to sanction
While export controls impact every country, there are stringent prohibitions on shipments and interactions with countries considered by the U.S. Department of State to be state sponsors of terrorism, known to have repeatedly provided support for acts of international terrorism: Cuba, Iran, North Korea, and Syria. Additional sanctioned countries appear on the Department of Treasury and the Department of Commerce websites.