Icahn School of Medicine at Mount Sinai is in the process of implementing procedures to address the activities listed throughout this website. For instance, the export, re-export, or transfer of all “controlled” materials, equipment, software, or technology to a third party must be made pursuant to a Material Transfer Agreement (MTA) or Data Transfer Agreement (DTA). Icahn Mount Sinai Parties must also confirm that they do not hand carry controlled materials and equipment outside the United States without prior review and approval by the Export Control Officer.
All Icahn Mount Sinai parties who participate in activities involving “controlled” items must receive and document training on the basics of U.S. export control and sanctions compliance. Specialized training will be offered on an as-needed basis, as determined by the Export Control Advisory Committee.
The Export Control Officer will provide guidance and assistance with export control compliance and review activities that may be subject to Export Control Laws.
Export Control Laws contain specific recordkeeping requirements that must be satisfied. Individuals are responsible for maintaining either hard or electronic copies of all import and export documentation, including determinations that export rules do not apply or that a license exception is available to the project or situation, and entry documents and such other documents to support the tariff classification, customs valuation, country of origin, marking/labeling, quantity, and other information provided on entry documents, for a period of not less than five years consistent with Icahn Mount Sinai’s document retention policy. All responsible Icahn Mount Sinai Parties should have a clear documented understanding of who will retain the documents in a given situation.
How Export Control Laws May Apply to You
Activities that may be subject to Export Control Laws include, but are not limited to:
- Research and collaborations (whether in-person or remote)
- Technology transfer and licensing
- International travel (including hand-carried baggage)
- Foreign persons at Icahn Mount Sinai (including researchers, staff, students, or visitors)
- Purchasing, payments, and other financial transactions
Examples of activities involving information transfer that could result in “exports control oversight” include:
- Having any Foreign Person (including foreign students, post-doctoral researchers, or colleagues) visit the areas at Icahn Mount Sinai in which export-controlled research is being conducted (which could be a Deemed Export)
- Having a Foreign Person work on a research project or in an Icahn Mount Sinai area involving access to export-controlled technology (e.g., a Foreign Person accessing third-party technical data related to the production of a controlled pathogen that is not eligible for the FRE, which would be a Deemed Export)
- Emailing export-controlled information from a research project to a Foreign Person colleague or sponsor
- Presenting export-controlled technology at a non-public conference or meeting
- Providing export-controlled technical assistance or instruction to a Foreign Person either in the United States or abroad
Attending or presenting at open meetings and conferences are exempt, if the event is open to all qualified individuals and attendees are allowed to take notes. An exception would be presenting at a meeting or conference hosted by or for the benefit of an embargoed or sanctioned entity, which would require a license from the Office of Foreign Assets Control. Educational information, including basic scientific and engineering principles and concepts, as well as the content of catalog-listed courses at associated teaching labs, is exempt.