Export Compliance Procedures

On this page you will find information about current processes and procedures related to required or recommended export reviews for certain Foreign Transactions as outlined in University Policies AD89, ADG09, RA40, or RAG40. Links to either online or PDF review requests forms will also be available here. Specifically, export review procedures and forms for the following types of Foreign Transactions are available from this page:

  1.  Foreign Visitor Reviews
  2.  Foreign Travel Reviews
          For Penn State Travelers
          For Non-Penn State Travelers
  3.  Foreign Shipment Reviews
  4.  Online Export Review Request Submission Forms
 

  • Foreign Visitor Reviews: Export violations can occur by sharing information, technology, or software and/or providing access to controlled equipment, materials, or research to a foreign national in the U.S. at University facilities. To mitigate this risk and as part of the University Export Management and Compliance Program, all foreign visitors should be cleared prior to arrival at University facilities. 

    For foreign visitors arriving under J-1 or H1-B Visa sponsorship by the University, the required export review will be initiated automatically through the internal iStart system. For all other incoming foreign visitors, a review should be obtained from the University Office of Export Compliance prior to the arrival of the foreign visitor(s). To facilitate completion of such a review, please either contact the Export Compliance Office for assistance or use the available online Export Compliance Review Request Form - Short-Term Foreign Visitors and indicate on the form the nature of the proposed visit.

  • Foreign Travel Reviews: International travel presents significant export compliance concerns, including, but not limited to, issues related to formal involvement with restricted or denied parties and foreign shipment and/or hand-carry of controlled items, information or software to foreign destinations. 
    • For Penn State Travelers:  Under University Policy AD89, all University Persons must request a pre-travel review of planned international travel activities undertaken for official University business purposes prior to departure.  No export review is required for purely personal travel events or for travel by students for non-University business purposes.  

      The required export review of any covered international travel will be handled by the trained Export Compliance Specialists and staff within the University Export Compliance Office, including any travel related to or funded under a Sponsored Research grant, contract or any other award vehicle. This pre-travel export compliance review is not an approval process but serves as the means to help to identify and mitigate export compliance "red flags" (risks) prior to the commencement of international travel activities.

      To facilitate the completion of an export review of foreign travel for University business purposes, University Persons may submit a request for review to the University Export Compliance Office by enrollment of the travel event in the Travel Safety Network (TSN) system as required under the University International Travel Requirements Policy. Export reviews for University Affiliated Travel will only be completed within the TSN system, so enrollment of all travel is recommended at least 30 days prior to departure.  For travel events which are not required to be registered in the TSN or when circumstances prevent registration in the TSN, please contact the University Export Compliance Office for the latest Export Review Request Form for foreign travel.  General questions about export compliance reviews of foreign travel may be directed to the UECO.
       
    • For Non-Penn State Travelers: For non-Penn State Persons traveling internationally at Penn State expense, an export review is still required due to potential liability that may be assessed to Penn State given our fiscal responsibility for the travel. Non-PSU travelers may enroll their travel in the TSN by contacting the TSN Staff to request access credentials for the TSN site. Alternatively, Non-PSU traveler activities may be reviewed for export purposes by following current processes for submitting such travel manually to the University Export Compliance Office for review. To request a copy of the current forms or procedures, please contact the University Export Compliance Office.
       
NOTICE:  For travel to any U.S. sanctioned/embargoed destinations (currently Cuba, Iran, North Korea, Sudan and Syria), travelers should contact the University Export Compliance Office via email as soon as the decision to travel is made. For travel to some destinations, such as Iran, a U.S. export license or other governmental approval may be required. Application for and receipt of such licenses may require 4-6 months of processing time.  
 

  • Foreign Shipment Reviews:  The shipment of commodities (items, materials, and goods) to international destinations is the most obvious example of an "Export", as that term is used under U.S. Export Controls. Penn State has a legal obligation under U.S. export and sanctions laws to comply with all such laws and regulations governing the international shipment of commodities.

    An online form is available to initiate an export review for the international shipment of hazardous or dangerous items or substances. PLEASE NOTE: An export review is a required part of the internal process for arranging shipment of such items by the Office of Environmental Health and Safety. This online form may also be used for other international shipments which are not handled by EHS if the shipping party believes that such items may be controlled items (commodities, technical data, software, etc.). When required, this online form should be submitted at least FIVE (5) days prior to the desired date of shipment, however additional advanced submission is highly recommended.

    Click here to access the Export Compliance Review Request Form - International Shipment of Hazardous and/or Potentially Controlled Materials.
     

  • Online Export Review Request Submission Forms:  In order to standardize and facilitate timely reviews of Foreign Transactions at Penn State, the University Office of Export Compliance has created a number of Online Export Review Request Submission Forms. These forms may be used to provide the trained staff in the University Office of Export Compliance with the necessary information to quickly assess the potential for export "red flags" in certain Foreign Transactions. University faculty and staff are encouraged to utilize the online forms to ensure that all necessary information is obtained at the time of submission. Use of the online forms will create efficiency in processing by reducing the need for additional conversations and/or information gathering by the compliance specialist reviewing the submission. Each online form includes basic instructions regarding the use of the form.
     
    • Export Compliance Review Request Form - International Shipment of Hazardous and/or Potentially Controlled Materials: 
      This form may be used to initiate a review of an international shipment of hazardous/dangerous or potentially export controlled items, materials, or information. The international shipment of hazardous/dangerous materials requires an export review prior to shipment per University Policy AD89 and University Guideline ADG09. Faculty and staff are also encouraged to submit other international shipments for review when they know or have reason to believe that the items to be shipped may be controlled under U.S. export laws. 
       
    • Export Compliance Review Request Form - Non-PSU Persons and University Supported Foreign Travel: 
      This form may be used to initiate an export review of foreign travel by non-PSU persons when such travel is to be reimbursed or purchased directly, in whole or in part, by the University. This form may not be used for University Persons (Penn State faculty, staff or students) who are required by the University International Travel Requirements Policy to enroll their travel in the Travel Safety Network (TSN).  Non-PSU Persons may contact the TSN Staff to enable access to the TSN system and, should they enroll their University supported travel in the TSN, this form would not be required (as the foreign travel review will be completed in the TSN system). For the purposes of this form, foreign travel is a trip to an international destination, not a trip from an international destination to the USA (and then back). As an example, faculty supporting travel by a collaborator using gift funds to cover expenses for the foreign collaborator to come to Penn State for meetings is not foreign travel (as the destination is domestic) but should be considered a short-term visit (see Short-Term Foreign Visitor Form below). However, the same use of funds to cover the expenses of a non-PSU person related to their travel to an international conference would be considered foreign travel which should be reviewed using this form.
       
    • Export Compliance Review Request Form - Short-Term Foreign Visitors: 
      This form may be used to initiate a review of short-term, international visitors to Penn State where such visitors do not require formal Visa sponsorship by the University. Examples of short-term visitors in this category would include short-term visiting scholars, collaborators, and speakers. This form should not be used for any foreign visitors being processed through the University Office of Global Programs using the Global Programs iStart system.
       

Please contact the UECO and/or review applicable University Policies and Guidelines for answers to questions concerning additional activities which may be subject to U.S. export control laws and regulations.  More information about export compliance at Penn State and the answers to common questions may be found on our FAQ page.


AD89 - University Export Compliance Policy

ADG09 - Export Compliance Definitions, Procedures and Implementation Guidelines

RA40 - Compliance with Federal Export Regulations for Sponsored Research Efforts

RAG40 - Guidelines for Ensuring Compliance with Export Control Policy RA40

International Travel Requirements Policy