Export Controls
All items within the U.S. or of U.S. origin are controlled for export by the U.S. federal government. Research activities undertaken at MGH may be subject to Export Control Regulations via these methods of export:
Shipment or transmission of items and certain information to individuals in prohibited countries,
MGH investigators traveling abroad to conduct research in restricted countries,
Transfer of information to foreign nationals, in our own labs or as collaborators, within the United States, or
Transfer of items or information to collaborators (domestic or international) who may then, in turn, transfer the materials to others for prohibited purposes.
Questions? Need to request training or education? Please contact Kele Piper.
NASA Funding Restrictions Related to Collaborations with China
In the 8/14/12 Partners Research Compliance Update, NASA awards will be subject to the restriction that funds may not be used to “develop, design, plan, promulgate, implement or execute a bilateral policy, program order, or contract of any kind to participate, collaborate, or coordinate, bilaterally in any way with China or any Chinese-owned company unless such activities are specifically authorized.” If you have questions about this restriction, please contact your Pre-Award GA or Kele Piper, Director, MGH Research Compliance
Policies and Guidance
PHS Export Control Policy (Requires Navigator Log-on)
PHS Export Control Guidance and Procedures
Export Control Presentation September 21, 2015
Resources: If the item or foreign national involved in your research is found on any of these lists, please contact Kele Piper. immediately. Please note: Specific items and situations may require additional review, please contact Kele Piper.
OFAC Sanctions Programs The list of foreign countries subject to US sanctions.
Nonproliferation Sanctions The list of countries, entities, and individuals sanctioned by the US for nuclear proliferation activities.
The Commerce Control List The CCL lists items, data, and technical information that is subject to US Export Control laws due to dual military and civilian uses.
The United States Munitions List The USML lists items, data, and technical information that is subject to export controls due to military applications.
List of Statutorily Debarred Parties The US State Department list of parties who have been convicted of violating the Arms Export Control Act.
Specially Designated Nationals List The list of parties whose assets are blocked by the US Treasury Department. US persons are generally prohibited from dealing with parties on this list.
The “Entity” List The list of entities identified by the US Commerce Department as subject to specific licensing requirements.
The “Unverified” List (BIS) The list of entities that were not able to be verified by the US Commerce Department in previous international transactions.
The “Denied” List (BIS) The list of persons subject to denial orders.
The MGH/MGPO confidential and anonymous Compliance Helpline: 617-726-1446
