Export control and U.S. sanctions laws affect whom you conduct financial transactions with, what you may purchase for on-campus use, and where you may purchase goods and services from.
Financial transactions include:
- Making payments, including:
- Engaging vendors or reimbursing collaborators
- Contest prizes
- Payments to research subjects
- Accepting payments, including:
- Membership fees for inclusion in MIT consortia, ILP, MITEI, etc.
- Research funding or awards
Screen for restricted parties
Screen people or organizations making or accepting payments for restricted parties, which will also catch if they are specially designated nationals or on other lists, such as Russian oligarchs. If there is a match, contact MIT Export Control.
Screen for comprehensively-sanctioned countries
You may not under most circumstances conduct financial transactions with:
- an individual or organization, company, university, or government agency of the comprehensively-sanctioned countries
- government owned organizations in Venezuela (including many of that country’s banks and universities)
If it is illegal to send a payment to someone, you cannot send it to a third party with instructions to forward. This is an attempt to circumvent the law and is a serious violation.
Review financial transactions with MIT Export Control
Purchases from outside the US
Before using your PCard to procure an item from outside the US, contact MIT Export Control. We cannot order from comprehensively-sanctioned countries or areas.
Tangible items, software, technology and measurement instrumentation
Even if your purchase is from the United States, contact MIT Export Control with the item’s Export Control Classification Number. (If using Buy-to-Pay, your procurement request will be automatically sent to MIT Export Control.) The US Government limits transfers of some technology and software to foreign nationals in the US (referred to as “deemed exports”). If an item is highly restricted, the VPR will need to approve a Technology Control Plan to protect the item and its technology.
Services
Contact MIT Export Control before purchasing a service. (If using Institute procurement, your request will be automatically sent to MIT Export Control.) Vendors providing services must always be vetted.