Policies & Procedures
Virginia Tech Policy Governing Compliance with U.S. Export and Sanctions Laws
Virginia Tech fully supports compliance with United States export and sanctions laws. These procedures have been enacted to establish, document, and implement actions needed to ensure that the university, and its employees and students, remain in full compliance with International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), Foreign Assets Control Regulations (FACR) and/or other applicable export control or sanction related regulations.
In accordance with federal regulations, Virginia Tech has established a Technology Control Plan (TCP) to control access by foreign nationals assigned to, or employed by, cleared contractor facilities. The purpose of this TCP is to ensure that the transfer of export controlled items, software, technology, classified information, or other unclassified but restricted data (e.g., For Official Use Only (FOUO), Naval Nuclear Power Information (NNPI)) is not to be conveyed in any manner to foreign national visitors, employees, and students beyond that which is approved for export by a license or other approval from the appropriate U.S. federal agency, or which is authorized to an individual possessing the required security classification and “need to know.”
Official procedure for the Office of Sponsored Programs (OSP) regarding management of agreements subject to export controls, sanctions, controlled unclassified restrictions, and/or security controls (“Restricted Research”). The procedure details the responsibilities of researchers, OSP, and OESRC in managing regulatory compliance with applicable U.S. laws, statutes, and regulations.
In accordance with the Controller’s Office Procedure 20335a: Travel Overview ALL international travelers (including presenters, students, visitors, and other business associates) whose travel expenses are to be charged to university public funds (e.g., sponsored programs, operating, various, etc.) are required to notify OESRC prior to the international travel. In addition to OESRC notification, Virginia Tech Policy 1070: Global Travel Policy requires all university-supported international travelers to register their travel with the Global Education Office (GEO) before their expected departure date and to provide updates as additional information becomes available or changes occur during the trip, including cancellations and travel to additional countries. To satisfy both OESRC and GEO international travel requirements, please follow the Procedure for Registering International Travel.
Virginia Tech is required by federal regulations to monitor assignments to its facilities of foreign nationals to ensure that the disclosure of, and access to, export controlled articles and related information are limited to those approved by an export authorization. In accordance with part 6 of the I-129 visa petition, Virginia Tech must certify whether or not an H-1B/H-1B1/L-1/O-1A applicant requires an export license. Additionally, International Affairs interim procedures require that the Office of Export and Secure Research Compliance (OESRC) review the following other non-immigrant visa petitions: J-1 visiting scholar, E-3, TN, and B visa/VWP visitors.
Prior to accepting any gift-in-kind, the unit or department is responsible for working with the university’s Office of Export and Secure Research Compliance (OESRC) to ensure that the gift is made in compliance with all sanctions, import and export regulations. If a gift is subject to such regulations, the unit or department must have prior approval from OESRC to accept and handle the gift appropriately. The Gift-in-Kind Transmittal Form provided by the Foundation for transmitting all gifts-in-kind includes a section for Restrictions on Use and Disposition addressing export control restrictions.