Export control spans multiple US government agencies which implement different laws and have varying goals. 


The U.S. Department of Commerce administers the Export Administration Regulations (EAR) which regulate the export of “dual-use” items. Dual-use items include goods and related technology, including technical data and technical assistance, which are designed for commercial purposes, but which could have military applications, such as computers, aircraft, and pathogens.

Items controlled by EAR are listed on the Commerce Control List (CCL). These are sometimes referred to as ‘list-based’ restrictions. An item’s EAR classification, destination country, receiving party, and end use all factor into whether a license is required for the export of an EAR-controlled item.  


The U.S. Department of State administers the International Traffic in Arms Regulations (ITAR) which regulate items and information inherently military in design, purpose, or use. ITAR regulations include defense articles, technical data, and defense services (assistance or training to non-US persons, whether or not in the United States, with respect to defense articles).

Items controlled by ITAR are listed on the US Munitions List (USML). Unless a specific exclusion or exemption applies, licenses are required for the export of an ITAR-controlled item.


The Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers economic sanctions programs with regard to a number of countries and regions. Some of these programs severely restrict transactions within that country or with entities or persons from that country, Many of the sanctions do not intersect with and are not relevant to MIT activities. Each sanctions program has an Overview of Sanctions document, and some offer additional guidelines.

OFAC also maintains the Specially Designated Nationals and Blocked Persons List (the SDN list), comprising: 

  • individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries
  • individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific

SDN-listed entities’ assets are blocked and U.S. persons are generally prohibited from dealing with them. Restricted Party Screening will identify whether entities are on the SDN list or are considered restricted parties.   

Executive Orders

An executive order is a directive from the President that has the power of a federal law. Restrictions and sanctions on people, governments and other entities can be mandated by Presidential Executive Orders.

Department of Energy (DOE)

10 CFR 810 regulates Foreign Nuclear Assistance and export of unclassified nuclear technology. DOE lists activities acceptable, activities prohibited, and activities requiring prior reporting to DOE. They also have an “A List” of countries that are less restrictive. 

  • Section 810.6 Generally authorized activities
  • Section 810.7 Activities requiring specific authorization

Nuclear Regulatory Commission (NRC) 

The Nuclear Regulatory Commission issues regulations under 10 CFR 110.8 and 110.9 concerning nuclear items, equipment, and material.

Homeland Security

Homeland Security regulates exports of Protected Critical Infrastructure Information (PCII), which arises when utilities and other national infrastructure assets are involved (for example, experiments performed on the US power grid).