Volume I: Academic and Research Affairs Chapter A: Education and Research Responsible Executive: Executive Vice President for Research Responsible Office: Office of the Executive Vice President for Research Date Issued: February 15, 2010 Date Last Revised: July 15, 2026
Contacts Statement of Policy Reason for This PolicyIndividuals and Entities AffectedExclusionsResponsibilities Definitions (defined terms are capitalized throughout the document)Related Documents, Forms and ToolsWebsite Address for This PolicyHistory and UpdatesAppendix
Empowered Official765-496-2518 | rsec@purdue.edu
Export Control Officer765-496-3605 | rsec@purdue.edu | RSEC Staff Contact List
It is the policy of Purdue University (1) to comply with all Sanctions and Export Control Regulations applicable to university activities, and (2) to develop and maintain a Sanctions and Export Control Compliance Program to enable Purdue Associates to understand and comply with these laws and regulations. No Purdue Associate may engage in any activity, or commit the University to engage in any activity, (1) that is prohibited by Sanctions and Export Control Regulations, or (2) that requires a license or other agency approval under Sanctions and Export Control Regulations, unless such license or approval has been obtained through Purdue’s Research Security and Export Controls (RSEC) team.
The regulatory framework created by Sanctions and Export Control Regulations has evolved over many years in different contexts to address a wide variety of national security and economic policy goals. The laws and regulations are extraordinarily complex, applying to university activities in ways that may not always be obvious.
The reach and complexity of Export Controls and OFAC Regulations have been steadily increasing in response to threats such as global terrorism, the proliferation of dangerous weapons, and other complex geopolitical developments. The global scope of Purdue activity has also been steadily growing. The University welcomes students and scholarly visitors, and employs researchers, scientists, and other Purdue Associates from countries throughout the world. Purdue engages in an enormous range of basic and applied research, often involving participation by Foreign Persons. Purdue Associates are engaged in activities and collaborations across the globe in furtherance of the University’s mission and strategic plan. Purdue purchases items from, and ships or delivers items to, many different countries.
These activities can intersect with Sanctions and Export Control Regulations in many different ways. The Office of Foreign Assets Control (OFAC), in the U.S. Department of the Treasury, administers Sanctions Regulations, which have been developed over the years to promote specific foreign policy and economic goals of the United States, primarily by blocking or restricting certain kinds of transactions (1) with designated individuals and entities, and/or (2) with respect to dealings with individuals, entities, and governments in a number of different countries.
The ITAR (International Traffic in Arms Regulations), which are administered by the Directorate of Defense Trade Controls (DDTC) in the U.S. Department of State, are designed to control the export and re-export of defense articles, defense services, and technical data.
The primary focus of the EAR (Export Administration Regulations) is to control the export and re-export of dual-use items—including commodities, software, and technology—that have both military and civilian applications. The Bureau of Industry and Security (BIS) in the U.S. Department of Commerce oversees these regulations.
Prohibited or restricted exports and services may occur under each of these regulatory regimes through the release of technology or software to Foreign Persons, even if the release takes place within the United States, as well as by shipping or delivering items, technology, or software to other countries. For example, it is possible for technology to be exported or services to be performed under these regulations by allowing a Foreign Person to participate in research in a lab in Indiana. While most university research is considered to be fundamental, and therefore not subject to Export Control Regulations, the possible applicability of these laws must be considered in various situations in which software and technology is subject to Export Control Regulations.
Various parts of Sanctions Regulations may be violated simply by purchasing from or selling to, or hiring or entering into collaborative relationships with, individuals or entities (1) from certain countries, (2) located in certain geographies, or (3) who are engaged in a variety of activities deemed to be contrary to defined national interests. Violations can occur in connection with transactions taking place entirely within the United States or when engaging in activities with U.S. citizens residing in places subject to comprehensive U.S. sanctions.
Additionally, federal agencies often restrict access to controlled research to U.S. citizens only or embed an additional layer of controls by subjecting information to Cybersecurity Maturity Model Certification or other categories of controlled unclassified information categorized as defense, export control, or intelligence.
Penalties for violations can be quite severe, potentially including large fines and imprisonment. This policy recognizes the need to enable Purdue Associates to understand and comply with these laws and regulations. In addition, creating and implementing an EC Compliance Program meeting federal guidelines can also mitigate the severity of any fines or penalties that might be imposed.
All Purdue Associates are potentially affected by this policy, depending upon the nature of their university duties and activities.
There are no exclusions to this policy.
President
Empowered Official
Export Control Officer (ECO)
Purdue Associates
Research Security and Export Controls (RSEC)
All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.
EAR The Export Administration Regulations, 15 C.F.R. Parts 730-774, as amended from time to time.
ECOThe Export Control Officer appointed by the Empowered Official.
Empowered OfficialAn employee of Purdue University appointed in writing by the President to serve in this role. The Empowered Official is defined at 22 CFR § 120.67.
Export Control RegulationsThe ITAR, EAR, their enabling statutes, and other federal regulations and enabling statutes controlling the export and re-export of goods, services, and technology, including in some circumstances releasing technical data, technology, or software or providing services, to foreign persons wherever located. Other United States agencies, including but not limited to the Nuclear Regulatory Commission, the Department of Energy, and the Patent and Trademark Office, also administer regulations controlling the export and re-export of commodities and technology within their jurisdictions.
Foreign PersonAny person who is not a lawful permanent resident of the United States, citizen of the United States, or any other protected individual as defined by 8 U.S.C. 1324b(a)(3). It also means any corporation, business association, partnership, trust, society or any other entity or group that is not incorporated in the United States or organized to do business in the United States, as well as international organizations, foreign governments and any agency or subdivision of a foreign government (e.g., diplomatic mission). Foreign Person is defined in the ITAR at 22 CFR § 120.63 and in the EAR 15 CFR § 772.1
ITARThe International Traffic in Arms Regulations, 22 C.F.R. Parts 120-130, as amended from time to time.
Prohibited Entity ListsAggregated compilations of individuals, entities, and organizations identified by U.S. government agencies as ineligible for certain transactions, funding, or collaborations. These lists typically consolidate multiple restricted party lists maintained by the U.S. Department of Commerce, U.S. Department of State, and U.S. Department of the Treasury into a single screening reference. Inclusion on Prohibited Entity Lists generally indicates that engagement is either barred or subject to heightened restrictions and approvals under applicable federal requirements and engaging with parties on Prohibited Entity Lists can impact eligibility for federal funding.
Purdue AssociateAn individual who is employed by, an agent of, or is affiliated with Purdue University. Examples of Purdue Associates include, but are not limited to, officers, faculty, postdoctoral research associates or research scientists, fellows and visiting scholars, undergraduate and graduate students, any person helping to conduct research at Purdue, and all other Purdue employees, wherever located and whether full-time, part-time, or temporary.
Restricted Party ScreeningThe process of checking individuals, entities, and organizations against government-maintained watchlists to ensure they are not subject to sanctions, export controls, or other legal restrictions. It is used to prevent prohibited transactions and ensure compliance with applicable laws and regulations. Screening typically occurs prior to engaging in business or academic activities such as collaborating, contracting, exporting, or financial transactions.
Sanctions and Export Controls Compliance ProgramThe program developed at the direction of the Empowered Official to do the following:
Sanctions RegulationsThe blocking and sanctions regulations administered by the Office of Foreign Assets Control (OFAC) in the U.S. Department of the Treasury, 31 C.F.R. Parts 500-598, as amended from time to time.
Research Security and Export Controls
Data Classification and Handling Procedures
Policies and Standards
Electronic Code of Federal Regulations
www.purdue.edu/vpec/policies/academic-research-affairs/ia2
July 15, 2026: Policy title changed from Export Controls and OFAC Regulations to align with relevant regulations. Included reference to Cybersecurity Maturity Model Certification in Reason for Policy section and added link to related standard. Added responsibilities for Empowered Official, ECO, and RSEC and removed EC Working Group. Updated definitions and related documents.
April 19, 2021: Administrative changes made to titles and offices and to remove procedures from the policy.
November 18, 2011: Policy number changed to I.A.2 (formerly VIII.6.1) and website address updated.
November 1, 2010: This policy supersedes the interim version dated February, 15, 2010.
February 15, 2010: This is a new interim policy.
There are no appendices to this policy.