Export Controls explained
In view of developments in Ukraine, College staff are advised to note updates to the relevant HM Government web pages, including those on sanctions and embargoes applicable to Russia. Further information can be found under section 3 on our ‘Do I need an export licence?’ page. Finally, please note suspension of extant Dual-Use licences to Russia, and Russia’s removal as a permitted destination from certain Open General Export Licences (OGELs).
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What are Export Controls?
UK Export Controls restrict the transfer or disclosure of sensitive goods, software, and technology (know-how and other information) to recipients and destinations outside of the UK. This includes physical exports, electronic transfers (via email, file sharing, virtual meetings, etc.), and transfers by any other means (verbal communication). Export control legislation applies to academic research and teaching in the same way as to trade and commerce.
Where do Export Controls come from?
UK Export Controls derive from international obligations, including those under UN Security Council Resolution 1540, the Chemical Weapons Convention, the Wassenaar Arrangement, and other treaties. They help to preserve national and international security by preventing Weapons of Mass Destruction (WMD) proliferation and countering terrorist threats. They also help prevent the violation of fundamental human rights including by torture, repression and capital punishment.
How do Export Controls work?
The UK Strategic Export Control Lists designate goods, software and technology that are controlled for the purposes of export. Other reasons for controlling items include concerns that the recipient may use them for military or WMD purposes, or for human rights violations. Where a transfer or disclosure falls under one or more of the applicable export controls, an export licence may be required. Licence applications and enquires are administered by the Export Control Joint Unit (ECJU) within the Department for Business and Trade (DBT).
It is important to consider whether you might require an export licence as early as possible when planning any research or teaching activity that involves overseas participants (students, collaborators, funders, etc.). The ECJU aims to turn around most licence applications within 20 working days. However, complex applications involving sensitive materials, regions or entities may take much longer (up to several months).
Researchers and other College staff are individually and personally responsible for their compliance with export control laws, including applying for the required export licence(s) where necessary. Failure to obtain a licence prior to a relevant transaction may result in criminal liability.