Skip to main content

When to reach out to ECIC

Northwestern researchers and their teams are responsible for understanding and complying with federal export control and research security regulations. The Export Controls & International Compliance office assists researchers and their teams with these compliance areas; however, the primary responsibility rests with the person engaged in covered activities. Violation consequences can be severe, including criminal and civil penalties. Please get in touch with Export Controls & International Compliance  with any questions or concerns.

This resource recommends steps to learn about export controls and research security compliance and provides a list of scenarios for when to reach out to the ECIC office.

Follow these steps to ensure compliance with export control and research security regulations:
  1. Familiarize yourself with NU export controls policy and federal regulations, including OFAC Sanctions.
  2. Familiarize yourself with research security policy and federal research security requirements for anyone applying or receiving federal funding. This includes:
  3. Take Research Security Training via myHR Learn. This training will be required starting May 1, 2025, for all DOE funding applications.
  4. Take Export Controls Training via myHR Learn or watch this video. Export controls training is required for all PIs on a Technology Control Plan or Risk Mitigation Plan.
  5. Review our international travel guidance before travel.
  6. Conduct due diligence by asking questions and contacting the ECIC team for a restricted party screening (RPS) or licensing determination in the scenarios below.
Reach out to the Export Controls & International Compliance (ECIC) office for guidance or a licensing determination for the following activities:

1) Any activities with heavily OFAC-sanctioned countries.

Many university activities—even virtual ones—with comprehensively or heavily sanctioned countries or individuals in those countries require U.S. federal authorization. Reach out to our office in advance of any activities with individuals in a comprehensively OFAC-sanctioned country or ordinarily resident in one of those countries.

  • Comprehensively OFAC sanctioned countries: Belarus, Cuba, Iran, North Korea, Russia, Syria, and certain regions of Ukraine (Crimea, Donetsk, Luhansk). Find other countries subject to sanctions programs in OFAC’s website.
  • Activities: Nearly all activities with individuals who are in or ordinarily resident of Cuba, Iran, North Korea, Syria, and the temporarily occupied regions of Ukraine (Crimea, Donetsk, and Luhansk), will require an OFAC license. This includes, but is not limited to:
    • Travel to a sanctioned country
    • Working or conducting research in a sanctioned country
    • Collaborating even virtually with individuals in a sanctioned country or ordinarily resident of a sanctioned country
    • Hiring anyone located in a sanctioned country*
    • Hosting a visitor who is ordinarily a resident of a sanctioned country (NU-Q) *
    • Allowing staff or students to work for Northwestern remotely from a sanctioned country
    • Allowing students to take remote coursework, including independent study from a sanctioned country
    • Making financial transactions (making or receiving payments)
    • Sending or receiving items physically or virtually via email/applications/cloud/other (technical data, source code, software, equipment, etc.)

 *Do not allow individuals from OFAC sanctioned countries start working until they arrive legally and physically to the U.S. or Qatar campus and do not issue a NetID until they arrive in the U.S. or Qatar. They may not work remotely from an OFAC sanctioned country under U.S. federal regulations and university policies.

2) International shipment or travel with items when they involve:
See ECIC International Shipping Guidance.
  • High Risk Countries - Everyday items such as laptops, cell phones, and certain communications devices and software may require a license or a documented exception under export regulations when shipped or carried to certain high risk countries. These countries change over time but are currently:
    • OFAC Sanctioned Countries: Belarus, Cuba, Iran, North Korea, Russia, Syria, and certain regions of Ukraine (Crimea, Donetsk, Luhansk).
    • Military End-Use (MEU) or Special Control Countries: Belarus, Burma, Cambodia, China (including Hong Kong), Iraq, Nicaragua, Russia, Venezuela.
  • Biological, chemical, or hazardous materials and accompanying technical data, regardless of country.
    • We recommend that you start by contacting NU’s Research Safety office. Hazardous materials shipping is regulated by the Department of Transportation and there are a range of government agency requirements. Research Safety will coordinate the review with the ECIC team.
  • A critical technology area, regardless of country. Example: quantum computing, integrated circuits, artificial intelligence capabilities, additive manufacturing, semiconductor materials, semiconductor manufacturing equipment, chip design software. List of critical technology areas (Annex).
  • Defense articles or military applications. Northwestern is not registered with the State Department DDTC, to handle/store/work with ITAR projects.
3) International travel to an OFAC or Military End Use country.

These countries change over time, but are currently, OFAC: Cuba, Iran, North Korea, Syria, and certain regions of Ukraine (Crimea, Donetsk, Luhansk). MEU: Belarus, Burma, Cambodia, China (including Hong Kong), Nicaragua, Russia, Venezuela. 

Also, review our international travel guidance before travel and submit a TMP form if needed. If traveling to an OFAC sanctioned country, register online.

4) Sending or receiving controlled technical data, object code, or source code.

Example: technical data coming from a sponsor marked ‘Confidential’ or ‘Export Controlled,’ or technical data that any researcher, sponsor, or contracting party have decided to keep confidential for national security or foreign policy reasons. This does not include data that you intend to publish, i.e. fundamental research.

Note: Fundamental research means research in science, engineering, or mathematics, the results of which ordinarily are published and shared broadly within the research community, and for which the researchers have not accepted restrictions for proprietary or national security reasons. See Guidance for Researchers.

5) Purchasing controlled equipment or materials. 

How will you know if an item needs a license or is highly controlled? See Purchasing Guidance. Procurement flags indicating that authorization may be required include:

  • The vendor requires you to sign an end-use certificate or export control statement. End-use certificates may only be signed by the appropriate university officer (not directly by staff, faculty, or students). 
  • Purchase order with strong export control language or EAR or ITAR-controlled markings.
  • The vendor notes shipping or foreign person restrictions.
6) Foreign Talent Recruitment Program membership.

Reach out to our office if you require guidance or are unsure that you are a Foreign Talent Recruitment Program (FTRP) and "Malign" Foreign Talent Recruitment Program (MFRTP) member, or whether the FTRP exclusions apply to your case.

7) Collaborations with individuals in foreign countries of concern.

FCOCs are China (including Hong Kong), Iran, Russia, North Korea. We recommend that you reach out to our office if you plan to participate or currently participate in activities with individuals affiliated to entities in FCOCs, as this may be considered a risk factor in future applications for federal funding. 

  • Example: Conducting research, sharing unpublished data, receiving support (financial or otherwise), collaborating on publications, continuing a collaboration, etc.
8) Risk mitigation is required from a U.S. federal sponsor.

Several federal funding agencies (DOD, DOE, NIH, NSF) have published information on how they assess certain international risk factors, and which factors may warrant mitigation or impact funding opportunities. The risk criteria differ by each agency, so it is important to review guidance from the agencies you work with or hope to work with carefully. See Federal Agency Risk Assessment Guidance. Our office will work with you to create and submit a risk mitigation plan if your federal sponsor requires it.

9) Hosting Research Visitors from High-Risk Countries 

Northwestern may not engage in transactions with a restricted party without prior government approval. 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 require screening before Northwestern sends an appointment letter to the Visitor confirming offer and terms. Use the Visitor Appointment process even for short-term visitors.
  • Can I host visitors affiliated/associated with a restricted entity? Northwestern will not routinely sponsor Research Visitors, including interns, on a U.S. restricted list or who are employed, supported or funded by a person or entity on a U.S. restricted list. There is a limited appeal/waiver process for certain instances. Our office will work with you to provide consultation and guidance. See Restricted Parties Research Visitors.
 10) Participating in controlled research.

See Guidance for Researchers. Some indicators of controlled research projects are:

  • The project is for research related to military or space items, or defense services.
  • The award or agreement contains foreign person restrictions or publication approvals, where you cannot openly publish.
  • See other indicators on our CERES Ancillary Review Checklist. We will work with your Research Administrator and Sponsored Research point of contact if any of these indicators are present in Northwestern sponsored research agreements.   
And anytime you have a question!