As a research organization, Smithsonian Astrophysical Observatory (SAO) is required by federal law to safeguard and obtain approval for the transfer of export-controlled hardware, software and technical data to non-US persons for projects that are outside of the "fundamental research" parameters. Export controls present unique challenges to SAO: They require balancing publication and open dissemination of research findings and results, (often with non-US persons), with export control requirements. These federal regulations' objectives are to reduce the risk to national security and U.S. economic vitality by restricting the transfer of technology to non-US persons from certain countries.
A violation of these regulations may lead to loss of research funding, significant monetary penalties, and in some cases, individual criminal action imposed by the U.S. Government if there is evidence that the act was determined to be willful.
Export Compliance personnel are responsible for identifying projects that may have both export restrictions and non-U.S. national participation, as well as analyzing what activities may subject SAO to certain export controls (e.g., collaboration with non-U.S. persons, foreign travel, or presenting research). The SAO Export Compliance Officer (ECO) is responsible for the day-to-day export/import operations and compliance oversight.
Natascha Finnerty, the ECO, will assist you with understanding the requirements, answer questions, identify ITAR- or EAR-controlled items/technical data that SAO handles, apply for the appropriate licences, and prepare Technology Control Plans (TCP), as necessary.
Possible controlled items for SAO: MS Word
Which U.S. Agencies Control Exports?
SAO is responsible for identifying projects that may have foreign national or export restrictions and analyzing what activities subject SAO to the controls of the:
Export Compliance: Countries With Export Restrictions
If your program has any involvement with countries or persons from sanctioned countries--Cuba, Iran, North Korea, Sudan and Syria--contact the ECO by email or at (617) 495-7449.
CONTACT US IF
- You think you may need to obtain a license for a non-US person to collaborate with your research
- SAO Non-US Collaborator Information Form: pdf
- If you are hosting non-US scientists, List of countries that do not require a Visa
- If your research is export controlled and you wish to work with a non-U.S. person who will be visiting from a foreign country, then this is an "export. If equipment being used by the non-U.S. person is export controlled, then we will need to obtain an export license. Foreign Group Checklist: MS Word
- Export License Procedures
- You need to export or import hardware
- You need to present a paper at a conference More Information...
- Your project is export controlled and you want to travel with your mobile device that has export controlled data
- You are not sure if your lab space meets ITAR best practices
- Encryption FAQ
Contact: Natascha Finnerty, Export Compliance Officer
firstname.lastname@example.org, (617) 496-7557, MS 23