Deemed Exports

Did you know?

A product does not have to travel across the U.S. border to be considered an export, and an export may not involve a product at all. Information and services may also be exported.

What is a “Deemed Export”?

A deemed export refers to the release of export-controlled technology or source code to any foreign national in the United States. A deemed export is treated as an export to that person’s home country. Deemed exports are a primary area of export control exposure for the university and apply to all activities at UMB, not just sponsored research.

Technology may be "released" for export by activities such as use of a controlled material, training on the use of controlled equipment, or dissemination of controlled research data and information by email or in conversations.

Review procedures

Review includes

  • Restricted party screening, that is, checking the U.S. government’s lists of restricted parties.
  • Assessment of the foreign national’s proposed activities at UMB.

Onboarding employees: The Deemed Export Control Form is a required form when onboarding foreign national employees (e.g., those on H-1B and Paid J-1 visas). This form identifies activities that might require an export license from the U.S. government before the foreign national can participate in that activity, unless the fundamental research exclusion or another exclusion applies.

I-129 Visa Petition Certification

Campus visitors: Visitor agreement procedures include deemed export review. Contact the Export Control Officer for assistance with export compliance if an international visitor will be escorted while at UMB and thus will not sign a visitor agreement (seminar speakers, for example).