Export Controls

Export controls regulations matter for the Saint Louis University community, even if your SLU program does not conduct research or receive federal funding.

Export controls are federal laws that restrict what information, technology and software can be exported, shipped, transmitted, transferred or shared from the United States to foreign countries, persons or entities. These laws aim:  

1. To restrict exports of goods and technology that could contribute to the military potential of U.S. international adversaries. 
2. To prevent the proliferation of weapons of mass destruction. 
3. To advance U.S. foreign policy goals. 
4. To protect the U.S. economy and promote trade goals. 

Export controls apply not only to physical shipments but also to electronic data transfers, international travel, and conversations with foreign nationals within the United States.  

Saint Louis University adheres to multiple federal agencies' regulations. The three primary regulations are: 

1. Department of Commerce, through the Bureau of Industry and Security (BIS) 
   Governs "dual-use" items under the Export Administration Regulations (EAR). These include commercial items with potential military applications. 
2. Department of State, through the Directorate of Defense Trade Controls (DDTC) 
   Oversees defense-related exports under the International Traffic in Arms Regulations (ITAR). This includes military equipment, services, and technical data.
3. Department of the Treasury, through the Office of Foreign Assets Control (OFAC) 
   Enforces economic and trade sanctions against foreign countries, entities, and individuals. 

Sanctioned Entities and Restricted Parties 

The U.S. government maintains several lists of individuals, companies, and organizations that are subject to export restrictions or sanctions (definitions of sanctions can be found here). These entities are sanctioned due to concerns such as terrorism, human rights violations, weapons of mass destruction (WMD) proliferation, or ties to adversarial governments. Saint Louis University and SLU personnel cannot be associated with a sanctioned entity or provide benefit to an entity on a sanctioned entity list.  

A few of the primary lists include:  

• Specially Designated Nationals (SDN) List – Individuals and entities blocked by OFAC. 
• Entity List- Parties requiring special licensing for exports due to national security concerns. 
• Denied Persons List – Individuals/entities denied export privileges. 
• Unverified List – Parties whose reliability could not be confirmed. 
• Military End User (MEU) List – Entities tied to foreign military activities. 
• AECA Debarred List – Entities barred from defense exports. 

International Travel

If you are traveling internationally, additional information is needed to ensure the University complies with current U.S. export-control laws and regulations. Refer to the international travel guide for requirements for international travel. 

Please respond with the answers to the following questions to michael.reeves@health.slu.edu prior to leaving for your trip. If you have previously responded to these questions for this trip, you do not need to send responses. 

1. What information, materials, or data (related to University business) will be taken, shipped, or shared outside the US? 
2. Are you taking SLU equipment (i.e., laptop, iPad, GPS, etc.)? If yes, Temporary Exports Export License Exception Certification. Please select "request service" to begin. 
3. Does your technology have any software that is not mass-market (Microsoft Office vs encryption source code)?  
4. Do you have any meetings planned with individuals/companies for professional purposes outside of your University business?  

Foreign Influence  

The University is committed to safeguarding the integrity of its academic and research activities from undue foreign influence. Foreign influence refers to efforts by foreign governments, entities, or individuals to improperly sway or exploit U.S. higher education institutions for strategic, economic or political gain.

Interim Malign Foreign Talent Recruitment Program Policy

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