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Policies & Services

Policies & Services

Immigration

The OEC reviews a variety of requests through the University’s Office of Immigration Services (OIS), Graduate Admissions, and International Student Services (ISS) to identify and mitigate potential risks of export controls violations which could arise when hosting international visitors.

We understand that the process of facilitating visa sponsorship takes time and effort and that visa denials may have reputational impacts. If you would like to request a preliminary review of a potential candidate prior to issuing an invitation or offer of employment or to ask questions prior to submitting an immigration request form to University immigration teams, please contact us at export@ou.edu or by calling 405-325-7843. 

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International Shipping

International shipments are one of many avenues by which items or information may be exported. In some cases, additional documentation or a specific export license from the U.S. Government may be required before an international shipment may occur compliantly. Seizures of goods, delays, and export violations can be prevented by working with the Office of Export Controls prior to shipping. To ensure that your upcoming international shipment is compliant, please complete OEC's International Shipping Form.

It is also recommended that you contact the University’s Office of Technology Commercialization (OTC) prior to shipment. OTC can advise and assist if a Material Transfer Agreement (MTA) is needed. MTA’s define and protect each party’s rights with respect to the materials, any derivatives and any resulting publication attribution. MTA’s may also provide an additional measure of assurance that materials will not be used in contravention of U.S. export regulations.  

High Risk/Restricted Party Policy

The U.S. Government publishes a variety of lists which identify individuals, companies, universities, NGOs, and other entities or groups who are considered parties of concern and a red flag when present in collaborations, transactions or exchanges. In some cases, these restricted parties may be outright prohibited by export and sanctions regulations. The Office of Export Controls screens for potential matches on these lists through administrative functions across the University. However, faculty and staff may also individually request a restricted party screening by providing the relevant details through OEC's Restricted Party Screening Request Form. The OEC will reply with the screening results and appropriate guidance, consistent with U.S. export controls requirements and with the University’s “High Risk and Restricted Parties Policy”, to assist you in making more informed decisions about risk and compliance within international engagements.

Hosting Non-Citizen Visitors on Campus Policy

The Office of Export Controls reviews proposed campus visits of non-citizen visitors who are not excluded from the scope of the University’s “Hosting Non-Citizen Visitors on Campus Policy”. These reviews are designed to enable the University to continue hosting non-citizens on campus while reducing risk and protecting the interests of OU and its community. In particular, the OEC seeks to identify and mitigate potential export controls violations and research security risks.

University hosts may submit the information requested by the policy to export@ou.edu. The OEC will then review and respond with appropriate guidance and, as needed, risk mitigation plans. University hosts are responsible for ensuring the policy’s guidance and best practices are followed throughout an approved visit. 

International Travel

Export controls are one of many considerations to make when planning an international trip. By carrying an item, sample, material, information, or software out of the United States, even temporarily, you are effectively exporting it. This includes cell phones, laptops and the data that may be stored on those devices.

In some cases, exports may require an approved export license from the U.S. Government or other documentation prior to your departure. This is especially true if you are traveling to or through a comprehensively sanctioned region or country or traveling with controlled items or data. Depending upon which agency has jurisdiction, approvals of a license application can take anywhere from 2-12 months, and the U.S. Government may approve or deny the request. The OEC will coordinate and submit the export license application; however, the OEC cannot guarantee that the U.S. Government will approve the request or issue a license within a specific timeframe. It is recommended to contact the Office of Export Controls well in advance to allow time for this lengthy approval process.

In many other cases, the University may not necessarily need to seek a license prior to your departure if the proposed trip qualifies for a specific export license exception, exemption, or a general license. The OEC will evaluate and make this determination and can provide a travel letter to accompany faculty and staff upon request. This may be helpful when moving through customs. Please note that U.S. Customs and foreign customs agents may be authorized to detain you and search and seize your electronic device without probably cause.

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Recommended Best Practices

  • Pre-register your international trip in the University’s International Travel Registration Portal to comply with the University’s "International Travel Registration & Review Policy". Please answer all questions in the registration ticket as accurately and comprehensively as you can. This enables the OEC to provide appropriate approvals and tailored guidance. Per the policy, pre-registration must be submitted at least 30 days prior to your departure date. However, the OEC would recommend that you pre-register at least 6 months in advance if you intend to travel to or through a comprehensively sanctioned country or region or if you intend to travel with export controlled items or information. The OEC may deny your proposed trip if export licenses and other required approvals are not requested and obtained in time.
  • Pursue other relevant notifications and approvals, such as from your department, University immigration teams, and other groups applicable to you. Depending upon the situation, you may also need to seek approval through OU HR’s International Remote Work Review Process. Researchers may also need to contact the HSC Office of Research Administration (ORA)/Norman Office of Research Services (ORS) to verify that – if your proposed travel is governed by the terms of any funding sources or specific research awards – any associated obligations or requirements have been met prior to departure.
  • Contact your department’s IT Specialist to ensure that your device is secure and compliant with OU IT’s cybersecurity requirements. The OU IT Security team (grc@ou.edu) is available to answer questions regarding IT policies and to provide additional support. 
  • Consider requesting a loaner “clean laptop” for your trip. The University maintains loaner devices which are “clean” or free of export-controlled technology, student records, HIPPA information, unpublished research data, and other sensitive information. Traveling with a clean laptop instead of your OU work laptop greatly reduces the risk of loss, theft, or inadvertent disclosure of protected information. All faculty and staff are welcome to request a clean laptop; however, priority will be given to those who are subject to a Technology Control Plan (TCP).
  • Evaluate and consider removing any non-essential data from devices prior to departure. To protect unpublished or other sensitive data, the Office of Export Controls recommends that you only travel with data that is necessary for the purposes of the international trip. Back up any data you do take, and leave backed up copies at home.
  • Request a Restricted Party Screening (RPS) for any companies, universities, groups, or individuals you intend to collaborate, visit, or engage with while traveling. This ensures you don’t unknowingly engage with a restricted party in violation of U.S. export controls. Screenings will be performed on entities listed in your international travel registration ticket. RPS requests may also be individually requested by completing an RPS request form.
  • Stay on your Fundamental Research topic and published information. Refrain from engaging in theoretical or developmental topics or agreements that could inadvertently disclose confidential or proprietary information. If you would like to discuss these topics or exchange these types of information further with international collaborators, the OEC recommends that you exchange business cards with a potential new collaborator. When you’ve returned from the trip, the University can assist in establishing a non-disclosure agreement or confidentiality disclosure agreement to govern and protect the exchange of information. Having an agreement in place prior to any further discussions protects you and the University from export controls risks.
  • Be cautious of any gifts, flash drives, or other items you may be given. A USB drive may contain malware and compromise your device and data.  
  • Refrain from doing research for contacts until you have discussed the proposed collaboration with the OEC. The OEC is available to assist you in evaluating whether an invitation to collaborate may lead to your involvement in a malign foreign talent recruitment program or other engagement prohibited by U.S. export controls.  
  • Consider requesting an OU IT Security assessment of your device to identify any malicious software you may have unknowingly acquired while abroad.
  • Submit an RPS request to the OEC for any potential new collaborators or affiliations.
  • Contact OEC for support if you encountered unusual, concerning, or suspicious individuals or solicitations while abroad. This could be an indication that there is an existing, more significant risk of exploitation to address.