Export Controls

The fast growth of Hackensack Meridian Health’s research enterprise has increased our international presence – both outside U.S. borders and also inside the U.S. with international scholars. Hackensack Meridian encourages international collaborations. Export control compliance ensures HMH adheres to federal export control regulations. Violations of export control regulations can result in significant civil and criminal penalties. 

What are “Exports?” 

Exports are any items (such as commodities, software, technology) sent from the U.S. to a foreign destination. These also include the release of information (oral or written) to foreign nationals within the U.S. (“deemed exports”).

What are “Export Controls?”

Export controls are the federal laws that regulate the export of sensitive technologies, equipment, software, biological agents and related data and services. These include:

• U.S. Department of Commerce Export Administration Regulations (EAR)
• U.S. State Department International Traffic in Arms Regulations (ITAR)

Export Controls and Research

Regardless of funding, laws must be followed, even for research. Fundamental research is not subject to license requirements, but there may be other requirements for foreign engagement. Fundamental research is basic or applied research in which the output of the research may be freely shared with the scientific community and there are no personnel restrictions on participation in the research based on nationality.

Export Control Compliance and Safeguards

All research projects are reviewed during contracting and negotiation to ensure HMH is abiding by policies and export control regulations. It is essential that all HMH researchers follow HMH’s standard operating procedures for sponsored research activities and avoid negotiating outside HMH’s processes. 

International projects and international visiting scholars require additional reviews and approvals.

Resources

• Export Controls and Research at HMH