Forms, Policies & Procedures

Here you will find a repository of forms, policies and procedures related to research at the University of Delaware. This repository draws on sources throughout campus to provide quick and easy access to these resources in a variety of formats, such as html, MSWord and Adobe PDF. We encourage you to explore and use the tools provided to narrow your search by word, resource type or category in order to learn more about the content that governs research at UD.


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RO Forms, Policies, and Procedures Search 2019

Animal Subjects in Research

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Conflict of Interest
Contracts and Grant Management
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Export Regulations (ITAR/EAR/OFAC)
Human Subjects in Research
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RO Forms, Policies, and Procedures Search 2019

Policy: Research Office

Export Regulations for Online Courses

Online Courses

Export controls and trade sanctions must be considered and, unless specifically excluded, applied to online courses. As is generally the case with universities, UD online courses possibly may be excluded from export control and trade sanction regulations.

  • Per EAR regulations, information and software that “are released by instruction in a catalog course or associated teaching laboratory of an academic institution” are not subject to the EAR. 15 CFR 734.3(b)(3)(iii). Please note that some encryption technology is excluded from this EAR exclusion.
  • Per ITAR regulations, the definition of Technical Data subject to ITAR “does not include information concerning general scientific, mathematical or engineering principles commonly taught in schools, colleges and universities.” 22 CFR 120.10(b).2
  • OFAC legislation provides in 50 USC 1702(b)(3):
      (b) The authority granted to the President by this section does not include the authority to regulate or prohibit, directly or indirectly—

      (3) the importation from any country, or the exportation to any country, whether commercial or otherwise, regardless of format or medium of transmission, of any information or informational materials, including but not limited to, publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks and news wire feeds.

    UD courses generally may be classified as “information and informational materials.” The online presentation does not alter this characterization. Therefore, pursuant to the OFAC legislation cited above, online courses typically are not OFAC-prohibited.

  • Exclusions do not apply to all subject matter that may be presented in online courses. The provision of principles not commonly taught in schools, colleges and universities, defense services, ITAR technical data, encryption technology and nuclear technology may not be excluded from control. Online-course instructors of such topics shall complete the export control training found at: http://www1.udel.edu/research/swf/UD-export-controls-training/
  • Online courses cannot be taught to students from OFAC-sanctioned countries without a license. Currently comprehensive or selective sanctioned countries include the Balkans, Belarus, Burunda, Central African Republic, Cuba, Democratic Republic of Congo, Iran, Iraq, Lebanon, Libya, North Korea, Somalia, Sudan and Darfur, Syria, Ukraine/Russia, Venezuela, Yemen and Zimbabwe. The list of sanctioned countries is updated periodically – https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.

Guidance for Foreign On-Line Education

Countries/ Regions*

Undergraduate Courses

Graduate Courses

Research

Export Control Concerns

Most Countries

Permissible

Permissible

Permissible

Low: Course and/or research-related materials should be examined by Research Office (RO)

Sanctioned Countries*

Permissible

STEM: Limited Permissible (Masters-level coursework; /capstone courses on case-by-case basis)
SOCIAL SCIENCES: likely permissible

Limited Permissible: Review/analysis/discussion of public domain information; otherwise, Case-by-Case permissible basis

High: Course-related materials should be reviewed by RO prior to shipping or electronic transfer Research-related materials and/or information should be reviewed by RO prior to permanent or temporary transfer

Cuba

Permissible

Problematic: Must be in U.S. on valid visa

Limited Permissible: Cuban scholars authorized to teach or conduct research, with restrictions

Restrictive: License required if student or scholar not in U.S.

Iran

Limited Permissible: undergraduate online courses in humanities, social sciences, law, or business are permissible

Problematic: Must be in U.S on valid visa

Problematic: Must be in U.S. on valid visa

Restrictive: License required if student or scholar not in U.S.

North Korea

Problematic

Problematic: Must be in U.S. on valid visa

Problematic: Must be in U.S. on valid visa

Restrictive: License required if student or scholar not in U.S.

Sudan

Problematic

Problematic: Must be in U.S. on valid visa

Problematic: Must be in U.S. on valid visa

Restrictive: License required if student or scholar not in U.S.

Syria

Problematic

Problematic: Must be in U.S. on valid visa

Problematic: Must be in U.S. on valid visa

Restrictive: License required if student or scholar not in U.S.

*This column refers to foreign nationals of the identified nationality participating in on-line education in that country.
Sanctioned countries include the Balkans, Belarus, Burunda, Central African Republic, Cuba, Democratic Republic of Congo, Iran, Iraq, Lebanon, Libya, North Korea, Somalia, Sudan and Darfur, Syria, Ukraine/Russia, Venezuela, Yemen, and Zimbabwe. The list of sanctioned countries is updated periodically – https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.

Questions regarding UD online course compliance with export controls and trade sanctions should be directed to UDresearch@udel.edu.

Related Links

 

Policy Details:

OWNER: UD Research Regulatory Affairs

RESPONSIBLE OFFICE: Research Office

ORIGINATION DATE: October 3, 2018

REVISION DATE(S): 5/13/19

Policy Source Email https://research.udel.edu/forms-policies-procedures/?entry=51652

ASSISTANCE

Compliance Hotline
Phone: (302) 831-2792

UD Research Office
210 Hullihen Hall
Newark, DE 19716
Phone: (302) 831-2136
Fax: (302) 831-2828
Contact us

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