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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Animal Subjects in Research
For Forms, Policies and Procedures pertaining to Animal Subjects in Research and other resources
Compliance
Conflict of Interest
Contracts and Grant Management
Effort Certification
Export Regulations (ITAR/EAR/OFAC)
Human Subjects in Research
Intellectual Property
Internal Funding
Material Transfer
Reporting Misconduct
Research Administration
Research Agreements
Safety
Students
Templates
University
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: https://research.udel.edu/training/#1
- 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) |
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 RO-Agreement@udel.edu.
Related Links
- Export Controls and Trade Sanctions Web Policy
- Export Controls and Trade Sanctions Memo PDF
- Export Regulations Web Policy
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