Export Control FAQs

International Travel

Send an email to export@gmu.edu. Our office will confirm that you have completed export training and, if not, we will enroll you in the training which is online and available via Mason Leaps. We will also provide you with a link to a one-page fillable laptop certification form. If you have already completed the training, you can go directly to our website and download and complete the Mason Laptop Export Certification Form: Export Control Forms - Office of Research Integrity and Assurance (gmu.edu)
Send an email to export@gmu.edu. Our office will confirm that you have completed export training and, if not, we will enroll you in the training which is online and available via Mason Leaps. We will also provide you with a link to a one-page fillable equipment certification form. If you have already completed the training, you can go directly to our website and download and complete the Non-Laptop Equipment Certification: Export Control Forms - Office of Research Integrity and Assurance (gmu.edu)
Yes. You can request a clean laptop by completing and submitting the Clean Laptop Short-Term Loaner Request on our website: Export Control Forms - Office of Research Integrity and Assurance (gmu.edu). Please request your clean laptop as soon as you make travel arrangements.
In general, the answer is no, you cannot take Mason owned laptops or equipment to a sanctioned country without a license from the U.S. Government. If you wish to take a Mason laptop to Cuba, send an email to export@gmu.edu. There is specific documentation that must be filed with the U.S. Government in order to take a Mason laptop to Cuba, and our office can file that paperwork on your behalf. Travelers can take personal laptops to sanctioned countries.
If you wish to travel to a sanctioned country on behalf of Mason, you must contact our office at export@gmu.edu. We need to preapprove all Mason travel to sanctioned countries to determine if we need a license from the U.S. Government.
  • If your travel is approved, you can take publicly available information with you, such as text books or other publications, and also personal belongings, such as your cell phone and personal laptop.
  • In general, you cannot take a Mason-issued laptop to a sanctioned country, regardless of the reason for travel unless you get a license from the U.S. Government. Unfortunately, these licenses take a lot of time to receive, and they often are not granted by the U.S. government.
  • It is permissible to take a Mason laptop to Cuba under certain, limited conditions, but you need to coordinate with our office because there are Federal filing requirements that our office must do in order to stay within compliance of the regulations.
  • There is no VPN or other remote access into the university local network while in a sanctioned country. You can still use your GMU email while in a sanctioned country and the library’s online resources. Effective May 5, 2022, DUO is restricting access to its service when it is accessed from countries or regions subject to U.S. economic sanctions. This affects access to Blackboard, Patriot Web, and any other University service that requires DUO authentication.
  • If you are traveling to a sanctioned country for purely personal reasons, then you do not need to talk to our office unless:
    • You wish to take Mason equipment with you, as that will require Mason to apply for a license from the U.S. Government, or
    • You wish to work on Mason-related projects while they are there because we will need to determine if a license is needed.
  • You will need a license from the U.S. Government if you wish to present a paper in a sanctioned country, answer questions regarding that paper, or, in some cases, even simply attend a conference there. This applies if you are attending or presenting on behalf of Mason. If you wish to attend or present at a conference in your own personal capacity on material that is not related to your Mason research, then you would not need a license from the U.S. Government.
  • If you attend or present at a conference in a non-sanctioned country, but you know that nationals from sanctioned countries may attend, you do not need a license from the U.S. Government.
  • You can send a copy of a paper you have presented to individuals in sanctioned countries. However, if the person who requests the paper asks you questions regarding it, you cannot respond without a license from the U.S. Government. You can publish a list of Frequently Asked Questions regarding the paper and direct people to those for more information.
Yes. Students are permitted to take publicly available materials such as publications or textbooks with them while they are travelling outside the U.S. and use those materials to complete academic course work. However, if a student is travelling to a sanctioned country*, they cannot conduct Mason related research, enroll in online classes, or work as a GTA or GRA while in that country. Sanctioned countries include the Crimea, Donetsk (DNR), and Luhansk (LNR) regions of Ukraine, Cuba, Iran, North Korea, and Syria.

Collaborations

It depends. You may need a license from the U.S. Government to collaborate with colleagues in a sanctioned country depending on which country is involved:
  • A license from the U.S. Government is almost always required if you want to collaborate with colleagues in Iran.
  • If you wish to collaborate with colleagues in Cuba on non-commercial research, then you would not need a license. However, certain requirements must be met, so you must contact our office at export@gmu.edu before beginning collaborations with individuals in Cuba so that we can review the activity, document our determination, and maintain the proper records.
Since licenses from the U.S. Government can take months, please contact us at export@gmu.edu as soon as you decide to pursue a collaboration.
It depends. For example, if the colleague is returning to Iran, then a license from the U.S. Government would be required to continue collaborations once the colleague leaves the U.S. Since licenses from the US Government can take months, please contact us at export@gmu.edu as soon as you decide to continue a collaboration.
It would depend on what restrictions the U.S. Government has placed on the individual or their institution. For example, some foreign universities are on the Commerce Department’s “Entity List,” which is a list of foreign persons, including some research institutions, who have engaged in activities that the U.S. Government considers to be contrary to U.S. foreign policy or national security interests. As a result, the U.S. Government has imposed export licensing requirements on these entities.
  • If you wish to collaborate with a colleague from an Entity List institution, you will not need a license if your project is considered fundamental research and you won’t be providing any export-controlled technology or information. However, you would need a license before collaborating with these researchers if your work is export-controlled or if you need to share export-controlled information or technology with your foreign colleagues.
Contact us at export@gmu.edu if you screen a colleague and they or their institution appears on one of these restricted party lists.
  • Screening is conducted using Visual Compliance. If your department does not have a Visual Compliance user who can perform the quick check screening, our office can conduct the screening for you, or we can set up someone in your department to be a Visual Compliance user.
  • Please note that an institution’s inclusion on a restricted party list is considered by the U.S. Government to be a red flag, and your association with such an institution may impact future projects or result in greater scrutiny, especially from sponsors such as DoD, NASA, and Energy.
  1. If you wish to use affiliates, then those affiliates must be screened against the various U.S. Government restricted party lists as part of the onboarding process. The screening is conducted in Visual Compliance. If your department does not have a Visual Compliance user who can perform the quick check screening, our office can conduct the screening for you, or we can set up someone in your department to be a Visual Compliance user.
  2. When onboarding an affiliate, you will need to complete the Affiliate Faculty Export Compliance Form: Export Control Forms - Office of Research Integrity and Assurance (gmu.edu). If the affiliate’s activities at Mason change significantly, for example if an affiliate who was not conducting research begins to do so, then you will need to complete a new form and submit it to our office.
  3. For the College of Science and the College of Engineering and Computing, if an affiliate is conducting Mason research, then the affiliate will need to complete online export training. Our office will enroll the affiliate in the training, and they will receive instructions from Mason Leaps on how to access the training.

International Shipping

Complete and submit the International Shipping Consultation Form: Export Control Forms - Office of Research Integrity and Assurance (gmu.edu) if you need to ship items outside the U.S.  Our office will determine if the shipment requires an export license from the U.S. Government or if a license exception applies. Even if such permissions are not required, we must still maintain records of all exports for five (5) years from the date of export.
  • Contact our office even if:
    • The item is returning to the U.S. (temporary exports may still require a license)
    • You are returning equipment to the manufacturer for repairs or replacement (a license may be required)
  • Yes. Anyone who ships an item outside the U.S. must maintain records of the export for five (5) years from the date of shipment. It is a violation if we do not maintain the proper records.
  • Make sure to keep the records in an easily accessible location. If the U.S. Government requests our export records, we must be able to produce the documents in a timely manner or risk fines and penalties.
  • Retain these records for all international shipments:
    • Invoices
    • Shippers export declarations
    • Air waybills
    • Shippers Letter of Instruction
    • Purchase Orders
    • Delivery Receipts
    • Emails describing the need for the export
    • Documents related to the Export Control Classification Number (ECCN) of the items to be shipped
    • Other miscellaneous documents related to the shipment

Activities Involving Sanctioned Countries

Sanctioned countries include the Crimea, Donetsk (DNR), and Luhansk (LNR) regions of Ukraine, Cuba, Iran, North Korea, and Syria.

  • It depends. Some activities related to publishing are permitted, but we must meet the requirements in the sanctions regulations and document that we meet those requirements. For example, if you are clearly in the process of publishing something with a colleague in Cuba, Iran, or Syria, then you do not need a license to engage in activities necessary to publish, such as communicating with your colleagues regarding the publication, editing the document, or adding items that enhance the work like photos, explanatory text, or search capabilities in electronic publications.
  • Publishing activities would not be permitted without a license from the U.S. Government, however, if the colleague is associated with their country’s government and is acting in their official capacity. The U.S. sanctions laws do not consider academic and research institutions to be part of the government, so publishing activities with people working at such institutions are allowed.
  • Contact our office at export@gmu.edu so that we can determine if you meet the requirements and to help you maintain proper records of the activity.
No, unless you get a license from the U.S. Government because serving as a reviewer would be considered a service to the journal.
It depends on the communication. Students will still have access to their GMU email account while in a sanctioned country and may use this to exchange emails with instructors or advisors at Mason. However, such communications may only relate to publicly available information, such as course schedules and other logistical questions. Students can access Blackboard, Patriot Web, and the library’s online resources, but will not have VPN or other remote access into the university network from sanctioned countries. Communications that are related to publishing between faculty and students located in sanctioned countries may also permissible, but you must notify our office first so that we can confirm this meets the regulatory requirements.
You can share publicly available information with individuals from sanctioned countries, so if you are providing them with information that is on the Mason website, for example, or if you are directing them to the website, that is permissible under the regulations. If there are specific questions that you frequently receive from prospective students, you could post that information to your department website (or your personal page on the website) and then direct students there.
Yes, peer review is permitted if you are simply determining whether or not to select for publication an article as submitted. Thus, you can review an article even if you know or suspect that the author is from a sanctioned country.
No, unless you get a license from the U.S. Government, because participating in an interview would be considered a service to the newspaper/website. You can direct them to publicly available information, such as your webpage or Mason’s website.
No, unless you get a license from the U.S. Government, because participating would be considered a service to the university. If you publish any papers related to your research, you can direct the university to these publicly available papers. You can also direct them to other publicly available information, such as Mason’s website. Please note that you cannot answer any questions related to your published papers without a license.
No. Effective May 5, 2022, DUO blocks access to its service when it is accessed from countries or regions subject to U.S. economic sanctions. These are the countries/regions where DUO restricts access (notice that this list includes Sudan which is no longer a comprehensively sanctioned country):
  • Cuba
  • North Korea
  • IranSudan
  • Syria
  • Ukraine - regions including:
    • Crimea region
    • Donetsk region
    • Luhansk region
    • Sevastopol region
Once DUO blocks service, users in these regions will see a DUO error message: "Access denied. DUO Security does not provide services in your current location." With DUO now required for access to Blackboard and Patriot Web (and any other University service that requires DUO authentication), individuals who travel to these countries/regions will not be able to use these services after May 5, 2022. If you are a student or faculty member who may be affected by DUO's blocking policy, please be aware of this issue if you intend to travel home and take appropriate actions before departing.

Fundamental Research

There are occasions when a sponsor will provide export-controlled materials for a project, but the results will still be published and, therefore, considered fundamental research. If you do get notified that the sponsor wants to provide you with export-controlled materials, contact our office at export@gmu.edu so that we can put a Technology Control Plan (TCP) in place and discuss secure computing options with you, if required. The TCP will provide guidance on how to safeguard the export-controlled materials so that we do not have an export violation.
Send an email to export@gmu.edu. We will put a Technology Control Plan (TCP) in place to ensure that export-controlled materials are properly safeguarded, and we will discuss secure computing options with you, if required.
  • Please let our office know if foreign students will need access to export-controlled materials so that we can apply for an export license or see if a license exception applies. You will also need to contact our office if you need to ship any export-controlled equipment or data outside the U.S.

Purchasing

  1. Screen the vendor against the various restricted party lists maintained by the U.S. Government using the Visual Compliance screening tool. If your department does not have a Visual Compliance user who can perform the quick check screening, our office can conduct the screening for you or we can set up someone in your department to be a Visual Compliance user.
  2. Request the Export Control Classification Number (ECCN) from the vendor or manufacturer and send it to export@gmu.edu. If you encounter problems obtaining the ECCN, send a description of the software and the name of the vendor to export@gmu.edu and we will contact the vendor and request the ECCN. Our office will let you know if there are any restrictions on who can use the software or whether it can be exported.
  1. Screen the vendor against the various restricted party lists maintained by the U.S. Government using the Visual Compliance screening tool. If your department does not have a Visual Compliance user who can perform the quick check screening, our office can conduct the screening for you or we can set up someone in your department to be a Visual Compliance user.
  2. Request the Export Control Classification Number (ECCN) from the vendor or manufacturer and send it to export@gmu.edu. If you encounter problems obtaining the ECCN, send a description of the equipment and the name of the vendor to export@gmu.edu and we will contact the vendor and request the ECCN. Our office will let you know if there are any restrictions on who can use the equipment or whether it can be exported.
  3. Contact our office if the equipment needs repairs or replacement and must be returned to a foreign vendor or manufacturer. We will determine whether an export license is required.
Back