Contact the Export Control Manager
Zachary Scott, Associate Vice President for Research Compliance and Tech Transfer
(406) 243-4755
Define “U.S. Person” vs. “Foreign National”
A “U.S. Person” is defined as a:
- Lawful Permanent Resident
- U.S. Citizen
- Legal Immigrant with a “Green Card”
- Protected Individual granted asylum or refugee status
“Foreign National” includes everyone else, including foreign governments or entities not incorporated to do business in the U.S.
Report Suspected Export Control Violations or Concerns
Any individual who suspects that an export control violation has occurred should notify the university through one of two channels:
- Contact the Export Control Manager directly at
- The Montana University System is pleased to offer a third-party Compliance Hotline that is available 24 hours a day, 7 days a week for employees, students and the public to anonymously report suspected noncompliance or other concerns
There are two ways to make a report to the MUS Compliance Hotline:
Call: 855-753-0486
Online: MUS Compliance Hotline
Individuals may report anonymously. The Export Control Manager will investigate the suspected violation by gathering information and will review the case in conjunction with the Office of Legal Counsel and the University Compliance Office to determine if a violation has occurred and if subsequent self-disclosure to a government agency is needed. If it is determined that a self-disclosure is needed the disclosure will be handled and submitted by the Export Control Manager, senior official and other empowered officials. Individuals who have concerns that a violation is about to occur should call the Export Control Manager directly.
Spot Red Flags
Activities which involve the following “red flags” may be subject to export controls:
- Contractual restrictions that destroy the Fundamental Research Exclusion:
- restrictions on the university’s right to publish or disseminate project results or information
- limitations on participation or access by non-U.S. Persons
- sponsor has prior approval rights over publication content (review is acceptable)
- Language in grant, contract, manufacturer, proposal or purchase documents that make specific reference to the International Traffic in Arms Regulations (ITAR)or Export Administration Regulations (EAR)(other than a general statement of compliance)
- When purchasing equipment vendor asks for “End User Certification” or similar signed statement that buyer will not export or allow foreign national access to equipment.
- Items or technical information produced for (or funded by) a defense, intelligence, or space related agency
- DoD, Army, Air Force, Navy, NSA, DHS, DARPA, IARPA, NASA or similar
- Research which involves:
- development of technology or equipment (may be for civilian use)
- defense, satellite, or space applications
- encryption technology
- biological or chemical threat agents and related medical remediation and diagnostics
- receipt of proprietary information from a sponsor
- Shipping or carrying controlled technology, equipment, or data overseas
- International collaborations where controlled data is shared
- Involvement with persons or entities from an embargoed or sanctioned country (Cuba, Iran, North Korea, North Sudan and Syria, others see OFAC Sanctions Programs)
- Unsolicited requests by foreign nationals to visit high technology facilities
Please contact the Export Control Manager for a personal consultation if any of the above conditions apply (______________). Even if there are no foreign nationals working directly on a project with export controls, a Technology Control Plan may need to be developed to protect controlled technology or data from unauthorized access (for example in an open-lab situation).