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Export Compliance: UW Export Glossary

Activity Director

Primary individual that has oversight and is accountable for the activity being carried out according to customer or sponsor requirements, the specific outcomes, and assumes a level of risk associated with the activity.

Arms Export Control Act AECA

22 U.S.C. 2778

Gives the President of the United States the authority to control the import and export of defense articles and defense services. It requires governments that receive weapons from the United States to use them for legitimate self-defense.

Australia Group Countries AG

15 CFR 740 Sup 1

This group was formed in 1984 to control the spread of chemical and biological weapons through licensing measures for exports in certain chemicals, biological agents, chemical and biological manufacturing facilities and equipment. Today, its member countries comprise of Argentina, Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Korea (South), Luxembourg, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Spain, Sweden, Switzerland, United Kingdom and the United States.

Authorized Person

A UW employee or student authorized to access Sensitive Unclassified Information (SUI) when the individual has been screened using the Access Request Form.

Automated Export System AES

15 CFR 30.1

AES is a nationwide system operational at all ports and for all methods of transportation through which export shipment data required by multiple agencies is filed electronically to Customs via an EEI.

Bona fide full-time employee

22 CFR 125.4(b)(10)

Full-time regular employee, whose permanent abode is in the U.S., the employee is not a national of an embargoed country.

Bureau of Industry and Security BIS

15 CFR 30.1

This bureau within the U.S. Department of Commerce is concerned with the advancement of U.S. national security, foreign policy, and economic interests. The BIS is responsible for regulating the export of sensitive goods and technologies, enforcing export control, antiboycott, and public safety laws, cooperating with and assisting other countries on export control and strategic trade issues and assisting U.S. industry to comply with international arms control agreements.

Carnet or ATA Carnet

15 CFR 30.1

A document for customs that permits sending merchandise temporarily into certain foreign countries without paying duty. The goods must return to the country of origin in order to avoid penalties.


The government may classify information that is deemed to be important to the national security interests of the United States. Classification is the means by which information is restricted. The standard categories of classification include confidential, secret, and top secret. A project that includes classified information is a sub-category of Restricted Research, defined below.

Classified National Security Information

Information that has been determined to require protection against unauthorized disclosure and is marked to indicate its classified status when in documentary form.

Commerce Control List CCL

15 CFR 744

The Commerce Control List is maintained by the Bureau of Industry and Security (BIS), of the US Department of Commerce, as part of the Export Administration Regulations (EAR) (http://www.gpo.gov/bis). The list of items is found in Supplement No. 1 to Part 774 of the EAR.

Commodity Classification Automated Tracking System CCATS

15 CFR 748.3(b)(3)

The classification system administered by the US Bureau of Industry and Security in which a requestor can obtain the export control classification number for products classified under the Commerce Control List.

Confidential Disclosure Agreement CDA

An agreement by which the parties agree not to disclose information shared.

Controlled Goods

Certain items that cannot be shared or transferred without obtaining license approval, using an exception, or otherwise obtaining approval from the cognizant agency.

Country Chart

15 CFR 738 Sup 1

The Country Chart helps exporters determine whether a license is required for export of items on the CCL to a given destination.

Country Group A

15 CFR 740 Sup 1

The countries listed under Country Group A maintain multilateral export control relationships with the United States.

Country Group B

15 CFR 740 Sup 1

Country Group B lists the "free-world" countries.

Country Group D

15 CFR 740 Sup 1

Exports for countries listed in Country Group D are controlled for various national security and non-proliferation reasons.

Country Group E

15 CFR 740 Sup 1

Countries listed in Country Group E are those for which exports are controlled under an embargo.

Country of Origin

15 CFR 30.1

The country where the goods were mined, grown, or manufactured or where each foreign material used or incorporated in a good underwent a change in tariff classification indicating a substantial transformation under the applicable rule of origin for the good.

Country of Ultimate Destination

15 CFR 30.1

The country where the goods are to be consumed, further processed, stored, or manufactured, as known to the USPPI at the time of export.

Criminal penalty

15 CFR 30.1

For the purpose of this part, a penalty imposed for knowingly or willfully violating the FTR, including failing to file export information, filing false or misleading information, filing information late, and/or using the AES to further illegal activity. The criminal penalty includes fines, imprisonment, and/or forfeiture.

Criminal Sanctions

Criminal sanctions, including fines of $50,000 or more and/or jail terms up to 10 years, may be imposed for knowing or willful violations of Export Administration Act and the

Debarred Parties List

22 CFR 127.7 and AECA 38(g)(4)

The persons (including entities and individuals) listed in documents linked below have been convicted of violating or conspiracy to violate the Arms Export Control Act (AECA). As a consequence, they are subject to "statutory debarment" pursuant to 38(g)(4) of the AECA and 127.7 of the International Traffic in Arms Regulations (ITAR).

Deemed Export Rule


Any release of technology or source code subject to the EAR to a foreign national. Such release is deemed to be an export to the home country or countries of the foreign national. This deemed export rule does not apply to persons lawfully admitted for permanent residence in the United States and does not apply to persons who are protected individuals under the Immigration and Naturalization Act (8 U.S.C. 1324b(a)(3)).

Defense article

22 CFR 120.3

Any item or technical data designated in 22 CFR 121.1. The policy described in 120.3 is applicable to designations of additional items. This term includes technical data recorded or stored in any physical form, models, mockups or other items that reveal technical data directly relating to items designated in 22 CFR 121.1. It does not include basic marketing information on function or purpose or general system descriptions

Any article that is specifically designed, developed, configured, adapted, or modified for a military application, and

  1. does not have predominant civil applicatio, and
  2. does not have performance equivalent (defined by form, fit and function) to those of an article or service used for civil applications;
  3. is specifically designed, developed, configured, adapted, or modified for a military application, and has significant military or intelligence applicability (examples are satellites, spacecraft and their subsystems, fully field-deployable systems for military use, and space-qualified for radiation hardened microcircuits); or
  4. is on the US Munitions List (USML, the US State Department ITAR list).
Defense Service

22 CFR 120.9

  1. The furnishing of assistance (including training) to foreign persons, whether in the United States or abroad in the design, development, engineering, manufacture, production, assembly, testing, repair, maintenance, modification, operation, demilitarization, destruction, processing or use of defense articles;
  2. The furnishing to foreign persons of any technical data controlled under this subchapter (see 22 CFR 120.10), whether in the United States or abroad; or
  3. Military training of foreign units and forces, regular and irregular, including formal or informal instruction of foreign persons in the United States or abroad or by correspondence courses, technical, educational, or information publications and media of all kinds, training aid, orientation, training exercise, and military advice. (See also 22 CFR 124.1.)
Directorate of Defense Trade Controls DDTC

22 CFR parts 120 through 130

The office at the Department of State responsible for reviewing applications to export and reexport items on the U.S. Munitions List.


The illegal transfer to unauthorized entities or destinations of controlled commodities.


15 CFR 730.3

Dual use covers particular items subject to the Export Administration Regulations that have both commercial and military or proliferation applications that are not also subject to the controls of the Department of State, Department of Energy, or the Nuclear Regulatory Commission. Some purely commercial items without an obvious military use are also subject to the EAR.


15 CFR 30.1

The export control classification number for items subject to the EAR but not specifically listed on the CCL.

Educational Instruction (EAR)

Information that is released by instruction in catalog courses and associated teaching laboratories is not subject to the EAR.

Educational Instruction (ITAR)

Information concerning general scientific, mathematical, or engineering principles commonly taught in schools, colleges and universities is not controlled by ITAR.

Electronic Export Information EEI

15 CFR 30.1

The electronic export data as filed in the AES. This is the electronic equivalent of the export data formerly collected as Shipper's Export Declaration (SED) information and now mandated to be filed through the AES or AESDirect.

Electronic Grant Application eGC1

Electronic internal compliance form that is routed with all grants and contracts for approval on campus before arriving at the Office of Sponsored Programs (OSP).


An embargo is a restriction on exports or imports with respect to the specific goods or ultimate destination of the shipment.

Empowered Official EO

22 CFR 120.25

A U.S. person who:

  1. Is directly employed by the applicant or a subsidiary in a position having authority for policy or management within the applicant organization; and
  2. Is legally empowered in writing by the applicant to sign license applications or other requests for approval on behalf of the applicant; and
  3. Understands the provisions and requirements of the various export control statutes and regulations, and the criminal liability, civil liability and administrative penalties for violating the Arms Export Control Act and the International Traffic in Arms Regulations; and
  4. Has the independent authority to:
    1. Enquire into any aspect of a proposed export or temporary import by the applicant, and(ii) Verify the legality of the transaction and the accuracy of the information to be submitted; and
    2. Refuse to sign any license application or other request for approval without prejudice or other adverse recourse.

15 CFR 772.1 and 15 CFR 31.1

A person or entity who receives US-origin commodities and uses them or incorporates them into other commodities. The person abroad that receives and ultimately uses the exported or reexported items. The end user is not an authorized agent or intermediary, but may be the FPPI or ultimate consignee.

Exclusion and Exemption

Applies only to transfer/disclosure of information, not to physical objects being transferred or the provision of defense services. An exclusion allows a Information is in the public domain (ITAR) or is publicly available (EAR). Exclusions apply to Fundamental research, Bona fide/full time regular employees and Educational Instruction. Exclusions do not apply to equipment, encrypted software, if there is reason to believe information will be used for WMD or where US government has imposed access and dissemination controls as condition of funding (ITAR). Exclusions are lost when the university accepts restrictions on publication of results or participation by foreign nationals in research. Exclusion are inapplicable to sponsor's existing information.


Shipment or transmission of items out of the US. Transfer of registration, control or ownership to a foreign person. Disclosing (oral or visual) or transferring technical data to a foreign person, whether on the US or abroad. Performing a defense service on behalf of, or for the benefit of, a foreign person.

Export Administration Regulations EAR

15 CFR parts 730 through 774.

Regulations administered by the Bureau of Industry and Security, that, among other things, provide specific instructions on the use and types of export licenses required for certain commodities, software, and technology. These regulations are located in 15 CFR parts 730 through 774.

Export Classification

Determination of an export control classification number, based on a review of the item or information against the the Commerce Control List.

Export Compliance

Applied regulations on all goods exported from a country including correct documentation, classification, licensing and screening (denied party/persons screening etc.).

Export Control Classification Numbers ECCN

15 CFR Part 738.2

An Export Control Classification Number is a numeric designator assigned to goods by the U.S. Department of Commerce, Bureau of Industry and Security (BIS). Each ECCN consists of five identifiers for category, product group, type of control, and country group level of control.

Export Control Compliance Program ECCP

The University of Washington's program to ensure campus-wide compliance with federal export control laws and regulations.

Export Controlled

Export-controlled items, software or technology are listed on either the Commerce Control List (CCL) or the United States Munitions List (USML). These items, software or technology are either prohibited from export, or require cognizant agency permission or licensing prior to the transfer or sharing of the items, software or technology.

Export controlled technology ECI

Technical data including data recorded or stored in any physical form, models, mockups or other items regulated by the EAR or ITAR.

Export license

A controlling agency's documented permission authorizing export of particular goods in specific quantities or values to a particular destination or to a foreign national (either in or outside the United States).

Export Regulations

Export regulations are the rules governing shipments from a different country including required documents and procedures, quotas to be adhered to, and/or restrictions on the shipment of certain items or to certain places/people.


For purposes of this document, individual at the University who will carry out the export. For instance, if a material transfer, the individual shipping or transmitting the material is the exporter. If sharing information with a foreign national, it is the individual sharing the information that is the exporter.

Facilities Security Officer FSO

DOD 5220.22-M 1-201

The FSO will supervise and direct security measures necessary for implementing applicable requirements of the NISPOM and related Federal requirements for classified information.

Faculty Council on Research FCR

Advisory body to the Faculty Senate on all matters of University policy relating to research and the primary forum for faculty - administrative interaction in determining that policy. See http://www.washington.edu/faculty/committees/fcr/

Foreign Corrupt Practices Act FCPA

22 CFR Part 709

The Foreign Corrupt Practices Act prohibits corrupt payments to foreign officials for the purpose of obtaining or keeping business.

Foreign Person

22 CFR 120.16

Persons who are not U.S. citizens, are not lawfully admitted for permanent residence in the United States, or are not persons who are protected individuals under the Immigration and Naturalization Act (8 U.S.C. 1324b(a)(3)). Foreign person includes individuals with study and work visas. For purposes of entities, any business or institution that is not a corporation, association, partnership, trust, society or other entity or group incorporated or organized in the United States.

Freight Forwarder

A business that arranges, handles and consolidates customers' exports for compensation.

Fundamental Research FR

22 CFR 120.11 and 15 CFR 734.8

Basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community, as distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons.

Fundamental Research Exclusion FRE

22 CFR 120.11 and 15 CFR 734.8

Information arising from basic and applied research in science and engineering at an accredited institute of higher learning within the U.S., where the resulting information is ordinarily published and shared broadly with the scientific community, is excluded from the scope of the EAR. In order to quality for the fundamental research exclusion under ITAR, the information must already by published.

General Technology Note

15 CFR 774 Sup. 1

The export of "technology" that is "required" for the "development", "production", or "use" of items on the Commerce Control List is controlled according to the provisions in each Category.

Group B Shipment (GBS) - License Exception GBS

15 CFR 740.4

For national security reasons only, controlled commodities for export and reexport to a given destination are authorized provided they are destined for a country listed under Country Group B.

Harmonized Tariff Schedule of the United States HTSUS

15 CFR 30.1

An organized listing of goods and their duty rates, developed by the U.S. International Trade Commission, which is used by CBP as the basis for classifying imported products, including establishing the duty to be charged and providing statistical information about imports and exports.

Immigration Customs Enforcement ICE

An agency within the Department of Homeland Security that is responsible for enforcing customs, immigration and related laws and investigating violations of laws to secure the Nation's borders.


Import Certificate IC

A document issued by the importing country's government and may be required in order to apply for a U.S. export license.

Imports (ITAR) ITAR

No defense article may be imported into the United States unless it was previously exported temporarily under a license issued by the Office of Defense Trade Controls; or it constitutes a properly licensed temporary import or in-transit shipment or qualifies for a relevant temporary import license exemption; or is authorized by the Department of the Treasury.

Intermediate consignee

15 CFR 30.6

The intermediate consignee acts in a foreign country as an agent for the principal party in interest or the ultimate consignee for the purpose of effecting delivery of the export shipment to the ultimate consignee.

International Emergency Economic Powers Act (IEEPA) IEEPA

To deal threats to the national security, foreign policy, or economy of the United States the International Emergency Economic Powers Act (IEEPA) grants the President authority to institute regulations covering commercial and financial transactions with other countries if a national emergency is declared.

International Traffic in Arms Regulations ITAR

22 CFR 120-130

Regulations administered by the Directorate of Defense Trade Controls within the U.S. State Department that provide for the control of the export and temporary import of defense articles and defense services. These regulations are located in 22 CFR 120-130.

Lawful Permanent Resident

Any person not a citizen of the United States who is residing the in the U.S. under legally recognized and lawfully recorded permanent residence as an immigrant. Also known as "Permanent Resident Alien," "Resident Alien Permit Holder," and "Green Card Holder."

License Applications - Defense Articles

Applications for licenses for the export of defense articles and related technical data must be made to the Office of Defense Trade Controls.

License Determination

A decision made by the government body with juristiction over trade in a commodity that a license should be granted to those making the request when specific conditions have been met.

License exception

15 CFR part 740

An authorization that allows a USPPI or other appropriate party to export or reexport under stated conditions, items subject to the EAR that would otherwise require a license under the EAR. The BIS License Exceptions are currently contained in Part 740 of the EAR.

License Exception (Limited Value Shipment) LVS

15 CFR 740.3

This License Exception, for all destinations in Country Group B, allows exports and reexports of eligible commodities with limited value

License Exception (Technical Data/Software Restricted) TSR

For national security reasons only and provided the software or technology is destined to Country Group B, Technical Data/Software Restricted permits exports and reexports of technology and software controlled to the ultimate destination.

License Exception BAG (Baggage)

15 CFR 740.14

Allows individuals departing the US to take with them as personal baggage family-owned retail-level encryption items including laptops, personal digital assistants (PDAs), and cell phones and encryption software in source or object code. The encryption items and software must be for their personal use in private or professional activities. Citizens and permanent resident aliens of all countries except Cuba, Iran, North Korea, Sudan and Syria (Group E Countries) may take with them as personal baggage non-retail "strong" encryption software to all locations except embargoed or otherwise restricted locations.

License Exception TMP (Temporary)

15 CFR 740.9

Allows those departing from the US on university business to take with them as "tools of the trade" UW-owned or controlled, retail-level encryption items such as laptops, personal digital assistants (PDAs), and cell phones and encryption software in source or object code to all countries except Cuba, Iran, North Korea, Sudan and Syria (Group E Countries) as long as the items and software will remain under their "effective control" overseas and are returned to the US within 12 months or are consumed or destroyed abroad.

License Exceptions

15 CFR 740

Under a License Exception, exports and reexports of qualifying goods or data require no prior written approval of the U.S. Department of Commerce.

Maintenance of Records (ITAR - DDTC)

22 CFR 122.5

Relevant records concerning the manufacture, acquisition and disposition of defense articles and the provision of defense services by the registrant must be maintained for a period of 6 years.

Manufacturing License Agreement MLA

A manufacturing license agreement represents a contract (written, implied or otherwise) whereby an entity or individual grants another entity or individual an authorization or a license to manufacture articles on their behalf.

Misrepresentation and omission of facts (ITAR)

22 CFR 127.2

It is unlawful to use any export or in-transit control document containing a false statement or misrepresenting or omitting a material fact for the purpose of exporting any defense article or technical data or the furnishing of any defense service for which a license or approval is required by the ITAR.

Missile Technology Control Regime Countries MTCR

22 CFR 120.29

Members countries are Argentina, Australia, Austria, Belgium, Brazil, Canada, Denmark, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Luxembourg, Netherlands, New Zealand, Norway, Portugal, Russia, Spain, Sweden, Switzerland, United Kingdom, and the United States.

National Industrial Security Proram - Opperating Manual NISPOM

DoD 5220.22-M

Provides baseline standards for the protection of classified information released or disclosed to industry in connection with classified contracts under the NISP.

No License Required NLR

15 CFR 772

NLR is a symbol entered on the Shipper's Export Declaration or an Automated Export System record certifying that an export license is not required.

Non-Disclosure Agreement NDA

NDAs may limit or prohibit, for proprietary purposes or security reasons, the disclosure or transfer of disclosed information. Research carrying publication, participation and/or dissemination limitations due to NDA restrictions for associated disclosed information used on a project may preclude characterization of the research effort as "fundamental research".

North American Free Trade Agreement NAFTA

15 CFR 30.1

The formal agreement, or treaty, among Canada, Mexico, and the United States to promote trade amongst the three countries. It includes measures for the elimination of tariffs and nontariff barriers to trade, as well as numerous specific provisions concerning the conduct of trade and investment.

North Atlantic Treaty Organization - Countries NATO

15 CFR 772

Belgium, Canada, Czech Republic, Denmark, France, Germany, Greece, Hungary, Iceland, Italy, Luxembourg, Netherlands, Norway, Poland, Portugal, Spain, Turkey, United Kingdom, and the United States.

Office of Foreign Assets Control OFAC

310 CFR 500-599

An agency within the U.S. Department of the Treasury that administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of weapons of mass destruction. The OFAC acts under Presidential wartime and national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze foreign assets under U.S. jurisdiction.

Original Equipment Manufacture OEM

OEM refers to the company that originally manufactured the product.

Outside party

Party that is not a UW Employee or Student but has certain responsibilities with respect to controlling access to SUI. This includes subcontractors, vendors, collaborators, consultants, volunteers, and visitors.

Principal Investigator PI

Person who takes direct responsibility for completion of a funded project, directing the research and reporting directly to the funding agency. Typically is the lead scientist or engineer for a particular science (or other research) project, such as a laboratory study or clinical trial.

Proprietary Information

Information protected by a sponsor or third party that is not generally known outside the sponsor or third party's organization and has access restrictions for commercial purposes. Proprietary information can include business plans, intellectual property, financial information or other business-sensitive information.

Proprietary Research

15 CFR Part 734.8(a)

Privately funded research activity undertaken pursuant to a contract between the University and an outside sponsor with commercial interests where the information shared by the outside sponsor and the research results are restricted contractually, such as publication restrictions or participation restrictions.

Protected person

8 U.S.C. 1324b(a)(3)

U.S. protected persons include political refugees and political asylum holders.

Public Domain (ITAR)

22 CFR 120.11 and 125.4(b)(13)

Information which is already published and generally accessible to the public through books, periodicals, patents, open conferences in the United States, websites accessible to the public with no access controls, or other public release authorized by the U.S. government.

Publicly Available (EAR)

15 CFR 772

Publicly available technology and non-encryption software, such as information that is the subject of an open patent application, published in a book or periodical, released at an open conference anywhere, available on a website accessible by the public with no access controls or information that will be published. This includes submission of manuscripts to journals for consideration with the understanding that the article will be published, if favorably received.

Reasons for Control

15 CFR 742

Reasons for Control are: Anti-Terrorism (AT), Chemical & Biological Weapons (CB), Chemical Weapons Convention (CW), Crime Control (CC), Encryption Items (EI), Firearms Convention (FC), Missile Technology (MT), National Security (NS), Nuclear Nonproliferation (NP), Regional Stability (RS), Short Supply (SS), Significant Items (SI), Surreptitious Listening (SL) and United Nations sanctions (UN). Items controlled within a particular ECCN may be controlled for more than one reason.


15 CFR 762.2

Supporting material and documentation concerning the manufacture, acquisition and disposition (copies of all documentation on exports using exemptions and applications and licenses and their related documentation), of defense articles or technical data. Records may be in electronic or hardcopy format but must be able to produce original format or ability to reproduce as in original format.


15 CFR 772

The shipment of U.S. origin products from one foreign destination to another. For statistical reporting purposes, it is those exports of foreignorigin merchandise which have previously entered the United States for consumption or into Customs bonded warehouses for U.S. Foreign Trade Zones.

Restricted Information

Data or other information that is generally circulated and subject to disclosure laws, yet sensitive enough to warrant careful management and protection to ensure its integrity, appropriate access and availability.

Restricted Parties Screening RPS

The review of names of individuals or entities against a list of individuals and entities that have been denied export privileges or with whom U.S. citizens may not carry out business, maintained by BIS, DDTC, OFAC and other governmental agencies.

Restricted Party Lists

Lists of individuals and entities that have been denied, debarred, sanctioned or prohibited export privileges or with whom U.S. citizens may not do business.

Denied Persons List
A list of individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order is prohibited.
Unverified List
A list of parties where BIS has been unable to verify the end-user in prior transactions. The presence of a party on this list in a transaction is a "Red Flag" that should be resolved before proceeding with the transaction.
Entity List
A list of parties whose presence in a transaction can trigger a license requirement under the Export Administration Regulations. The list specifies the license requirements that apply to each listed party. These license requirements are in addition to any license requirements imposed on the transaction by other provisions of the Export Administration Regulations.
Specially Designated Nationals List
A list compiled by the Treasury Department, Office of Foreign Assets Control (OFAC). OFAC's regulations may prohibit a transaction if a party on this list is involved. In addition, the Export Administration Regulations require a license for exports or reexports to any party in any entry on this list that contains any of the suffixes "SDGT", "SDT", "FTO", "IRAQ2" or "NPWMD".
Debarred List
A list compiled by the State Department of parties who are barred by 127.7 of the International Traffic in Arms Regulations (ITAR) (22 CFR 127.7) from participating directly or indirectly in the export of defense articles, including technical data or in the furnishing of defense services for which a license or approval is required by the ITAR.
Nonproliferation Sanctions
Several lists compiled by the State Department of parties that have been sanctioned under various statutes. The Federal Register notice imposing sanctions on a party states the sanctions that apply to that party. Some of these sanctioned parties are subject to BIS's license application denial policy described in 744.19 of the EAR (15 CFR 744.19).
Restricted Research

Research carried out in which there are restrictions placed on the research. Such restrictions include restrictions on access to facilities, restrictions on publication or dissemination of research results. Restricted research includes proprietary research, classified research, or research involving export-controlled information.

Schedule B

15 CFR 30.1

The Statistical Classification of Domestic and Foreign Commodities Exported from the United States. These 10-digit commodity classification numbers are administered by the Census Bureau and cover everything from live animals and food products to computers and airplanes. It should also be noted that all import and export codes used by the United States are based on the Harmonized Tariff System.

Sensitive Unclassified Information SUI

Unclassified information that does not meet the standards for national security classification, but is pertinent to the national interests of the United States, and requires, under law, policy, or contractual terms, protection from unauthorized disclosure, special handling safeguards, or prescribed limits on exchange or dissemination. SUI includes, but is not limited to: All unclassified information that is provided by a sponsor or third party under a sponsored research agreement, material transfer agreement, confidentiality agreement, or any other contractual arrangement, in which there are restrictions on dissemination or publication for national security purposes, or restrictions on transfer based on citizenship, and/or the government requires review prior to any dissemination, publication or transfer of the information; All unclassified information that has been marked with U.S. Government distribution limitations, whether or not it is related to a classified contract; or A ll unclassified information related with a classified contract that has not been approved for public release.

Shippers Export Declaration SED

15 CFR 30.1 and 22 CFR 120.28(b)(2)

The DOC paper form used under the FTSR to collect information from a person exporting from the United States. This form was used for compiling the official U.S. export statistics for the United States and for export control purposes.

Significant Military Equipment SME

22 CFR 120.7; 22 USC 2794(9)

Articles for which special export controls are warranted because of their capacity for substantial military utility or capability.


15 CFR 772

A collection of computer programs fixed in any tangible medium of expression. This includes system functional design, logic flow, algorithms, application programs, operating systems and support software for design, implementation, test, operation, diagnosis, and repair of defense articles.

Software and Encryption

Products with the following encryption functionality require review by the Department of Commerce, Bureau of Industry and Security prior to export: Software employing characteristics equal to or great than; a symmetric algorithm with a key length in excess of 56-bits and up to 512-bits for asymmetric key exchange algorithms, and 112 bits for elliptic curve or mass market software with key lengths exceeding 64-bits. (5A002

a.E1 )x cluding items using only limited cryptographic functionality (Category 5 Part 2, Related Control Note); Short-range wireless; Wireless PAN; or "Ancillary Cryptography" (740.17(b)(4))

Source Code and Object Code

15 CFR 772

Source code is generally understood to mean programming statements that are created by a programmer with a text editor or a visual programming tool and then saved in a file. Object code generally refers to the output, a compiled file, which is produced when the Source Code is compiled with a C compiler. The object code file contains a sequence of machine-readable instructions that is processed by the CPU in a computer. Operating system or application software is usually in the form of compiled object code.

Specially Designated Nationals SDN

31 CFR 500.305

The Office of Foreign Assets Control (OFAC) publishes lists of "Specially Designated Nationals", which are individuals and companies attempting to procure US-origin goods on behalf of an embargoed-sanctioned country.

Sponsored Project

Any exchange transaction between the University and the sponsor that may occur in a number of forms. A University sponsored project is not a purchase or sale of goods or services or "work for hire" arrangement but instead is a mutual exchange involving the University and a sponsor. Sponsors may provide funding, equipment or other tangible items, such as goods or services, for research, training, education programs, analytical services or other rights or goods.

Technical assistance agreement TAA

22 CFR 120.22

An agreement (e.g., contract) for the performance of defense services or the disclosure of technical data, as opposed to an agreement granting a right or license to manufacture defense articles.

Technical Data

15 CFR 772 and 22 CF 120.10

May take forms such as blueprints, plans, diagrams, models, formulae, tables, engineering designs and specifications, manuals and instructions written or recorded on other media or devices such as disk, tape, read-only memories. Also information required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance or modification of defense articles. All classified information relating to defense articles and services is technical data. In addition, all information covered by an invention secrecy order is considered technical data under ITAR. Technical data does not include basic marketing information on function or purpose or general system descriptions.


15 CFR 772

Specific information necessary for the "development", "production", or "use" of a product. The information takes the form of "technical data" or "technical assistance".

Technology Control Plan TCP

A University document that sets out the scope, policy and procedures to protect sensitive unclassified information that is within the possession, custory or control of UW Employees, Students or Outside Parties at the University. Specific project or activity security measures are set out in an associated Security Control Plan.

Temporary Export Licenses

22 CFR 123.5

The Office of Defense Trade Controls may issue a license for the temporary export of unclassified defense articles if it will be returned to the United States within 36 months and transfer of title will not occur during the period of temporary export.


15 CFR 742

A shipment, transmission, or release to any person of items subject to the EAR either within the United States or outside the United States. Incountry transfer/transfer (in-country) . The shipment, transmission, or release of items subject to the EAR from one person to another person that occurs outside the United States within a single foreign country.

U.S. Munitions List USML

22 CFR 121

Articles, services and related technical data are designated as defense articles and defense services pursuant to 38 and 47(7) of the Arms Export Control Act (22 U.S.C. 2778 and 2794(7)). Aticles deemed to be "Significant Military Equipment" to the extent specified in 120.. Certain defense articles and services are identified in 121.16 as being on the list of MTCR Annex items on the United States Munitions List.

U.S. Person

22 CFR 120.15

U.S. person means a person (as defined in 22 CFR 120.14 ) who is a lawful permanent resident as defined by 8 U.S.C. 1101(a)(20) or who is a protected individual as defined by 8 U.S.C. 324b(a)(3). It also means any corporation, business association, partnership, society, trust, or any other entity, organization or group that is incorporated to do business in the United States. It also includes any governmental (federal, state or local) entity. It does not include any foreign person as defined in 22 CFR 120.16.

Ultimate consignee

15 CFR 31.1; 30.6

The principal party in interest located abroad who receives the exported or reexported items. The ultimate consignee is not a forwarding agent or other intermediary, but may be the end-user.

Unauthorized persons

Individuals not authorized to access Sensitive Unclassified Information.

University of Washington (UW) Employee

For purposes of the Technology Control Plan, all faculty, librarians, academic personnel, professional or classified staff. It does not include students, visitors, or outside parties.

University of Washington (UW) Student

As defined by WAC 478-140-015, a person who is or has been admitted or is or has been officially registered in courses at the University of Washington for at least one day of an academic program and with respect to whom the university maintains education records.

Wassenaar Arrangement

This agreement between Australia, Austria, Belgium, Canada, the Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Luxembourg, The Netherlands, New Zealand, Norway, Poland, Portugal, the Russian Federation, the Slovak Republic, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States, is concerned with controlling exports of dual use goods.