Sanctions and Export Control Registrations and Licenses

Universities conducting research subject to U.S. export control regulations may need to register with federal agencies and obtain export licenses when necessary. Purdue's Research Security and Export Control (RSEC) team oversees these processes to ensure compliance with International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and the Office of Foreign Assets Control (OFAC) sanctions.

How RSEC Supports Researchers

RSEC assists faculty, researchers, and their teams by:

• Managing government agency registrations.
• Determining whether an export license is needed for a project or transaction
• Preparing and submitting export license applications
• Ensuring compliance with license conditions and maintaining accurate records
• Providing guidance to faculty and researchers on export control requirements

Registrations

Purdue University is registered with the Directorate of Defense Trade Controls (DDTC) and maintains an account with the Bureau of Industry and Security (BIS).

Directorate of Defense Trade Controls (DDTC)

Any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is required to register with the Directorate of Defense Trade Controls. Engaging in such a business requires only one occasion of manufacturing or exporting or temporarily importing a defense article or furnishing a defense services. Even if an organization does not engage in exporting, registration is required.

Registration is primarily a means to provide the U.S. Government with necessary information on who is involved in certain manufacturing and exporting activities. Registration does not confer any export rights or privileges. It is generally a precondition to the issuance of any license or other approval. DDTC registration requires annual renewal and associated fees.

Contractors often require universities to verify their DDTC registration status when entering into a contract or subcontract that involves ITAR-controlled technical data, defense articles, or defense services. Click here to request Purdue's DDTC Registration Confirmation Letter.

Bureau of Industry and Security (BIS)

Unlike DDTC, BIS does not require registration. Universities interact with BIS primarily when applying for export licenses for dual-use items, software, or technology controlled under the EAR (e.g., advanced semiconductors, aerospace materials).

To submit a license application, RSEC maintains an account in the Simplified Network Application Process -- Redesign (SNAP-R) system, which is used to manage export license requests and track submissions.

Office of Foreign Asset Control (OFAC)

While there is no formal registration, universities must comply with OFAC sanctions programs when working with sanctioned countries, entities, or individuals. Universities may establish an account in the OFAC License Application Portal to manage compliance.

Licenses

Purdue exports when it transfers or releases a controlled item, technology or software to a foreign person or foreign destination. Exports may be regulated through the International Traffic in Arms Regulations (ITAR) or the Export Administration Regulations (EAR). Depending on the item, technology or software being exported, the end user, the destination country, and the intended end use, an export license may be required.

Engaging with parties in Comprehensively Sanctioned Countries will always require some type of authorization from the U.S. Department of the Treaury's Office of Foreign Assets Control (OFAC). These authorizations come in one of two forms:

1. General Licenses: These operate like blanket authorizations to engage in an otherwise prohibited activity. While they are self-electing, RSEC has expertise in understanding these and researchers should not attempt to independently identify whether they qualify for a general license. Each sanctions program is different and unique; therefore, a General License that may exist for one sanctions program may not exist for another sanctions proogram.

2. Specific Licenses: When an activity cannot be authorized by a General License, an application may be submitted to OFAC for a Specific License.

RSEC maintains expertise in identifying whether an export license or OFAC Specific License is required and in obtaining licenses on behalf of Purdue. It is important to note that license applications can take 6 months or more for processing with the federal government. The government may return license applications without action, deny, approve with provisos, or approve license applications. Once obtained, they may be revoked at any time.

Whom should I contact at Purdue with questions about export registrations and licenses?

Please contact RSEC for guidance on export registrations or licensing concerns by emailing rsec@purdue.edu.