Export Compliance Section (Beta Site) Export Compliance News

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.

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: Natascha Finnerty, Export Compliance Officer
nfinnerty@cfa.harvard.edu, (617) 496-7557, MS 23


Export Compliance News and Updates

  • Obama Announces U.S. and Cuba Will Resume Relations (December 2014)
  • Office of Undersecretary for Finance and Administration Issues Notice About Export Compliance (September 2014)
  • REAL ID Act Affects Access to NASA Facilities (July 2014)
  • NASA Suspends Most Contact with Russia (April, 2014)
  • Harvard EdX Blocks Course Content to Cuba, Iran, Sudan (March 2014)
  • NASA IG Finds no Evidence of Intentional Export Control Violations at Ames (February 2014)
  • ITAR Export Control Reform - Status (January 2014)


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