At HMS, the Office of Research Administration's Research Security Team supports our community with Export Control and restricted Party Screening reviews. Contact them with any questions at: international_collaborations@hms.harvard.edu Additionally, many departments and units at HMS have someone trained on staff who can conduct Restricted Party Screens for individuals and entities that the department or faculty want to conduct business with. Please reach out for support.
Export Control laws broadly apply whenever items, services, technology, funds, or data are being sent (exported) outside of the United States, including when information and know-how is transferred to a foreign national located within the United States (a “deemed export”), regardless of the source of funding. Harvard Medical School is committed to complying with applicable U.S. laws and regulations pertaining to exports of items, services, technology, funds, or data by or on behalf of HMS.
The Harvard University Office of The Vice Provost for Research provides resources and information that support the HMS community in complying with Export Control and restricted Party Screening requirements.
Activities that require reviews include but are not limited to:
- Shipping, transporting or carrying Harvard-owned materials, data, equipment, or technology outside of the US
- Sharing unpublished data or information with person outside of the US
- Sharing unpublished information or data with non-Harvard affiliated foreign nationals (in US or abroad
- International research collaborations (sponsored or self-funded)
- Hosting anyone working outside of the US (even part-time)
- International appointees, employees, HSRs or visitors who are on a visa
- Granting systems and data access to someone who is located outside of the US
- Financial transactions with international vendors, subawards or collaborators
- Traveling abroad to conduct research outside of the US
- Traveling abroad with research materials, equipment or data
- All educational programs involving export-controlled content
- Educational services to individuals in or from a sanctioned country
- Payment of travel expenses or honorarium to non-US persons participating in an educational event
- International participants in educational activities where Harvard is hosting a conference outside of the US
- International participants in online educational activities that require registration, registration fees and/or are not open to the public
Resources:
Harvard Export Control Policy Statement
Training: An Introduction to Export Control Laws and Regulations
Export Control License Review and Approval
Harvard’s Openness in Research Policy
Appointments with Restricted Party Affiliations Guidance
Infographic: What Gets Reviewed for Export Controls
Infographic: When to request an Export Control Review or Restricted Party Screen
Infographic: Screening Educational Program Requirements
International Data Security Guidance