Export Control Menu
ORP Menu
Donations and Gifts
Did you know that donating or receiving certain research equipment, materials, or even financial gifts can trigger federal export control and sanctions regulations? Certain transfers require a review by the Office of Export Compliance (OEC) to ensure the University is following all export / import laws and regulations.
Things You Need to Know
- “Free” does not mean exempt: Federal export laws, import regulations, and sanctions still apply to gifted items, materials, and technologies, even when no money exchanges hands.
- It applies to both international AND domestic transfers: While international transfers have obvious export and import implications, accepting highly controlled technology or funds from a domestic U.S. donor can also trigger certain export compliance requirements.
- It applies to money, too: Accepting funding, endowments, or monetary gifts from a sanctioned country, or a restricted entity is a violation of Office of Foreign Assets Control (OFAC) regulations.
- You cannot “just give it away”: University property belongs to the University. Per University Policy FN14 giving equipment directly to outside individuals or organizations is generally prohibited.
When to Contact the Office of Export Compliance
You do not need to contact the OEC for standard, low-risk, domestic donations (e.g., basic office furniture or consumer laptops). However, an export review is mandatory if the donation involves:
- Controlled Items or Technology: Items that have an Export Control Classification Number (ECCN) or United States Munitions List (USML) category. For example, high-tech, specialized, or custom-built research equipment (e.g., lasers, sensors, aerospace components).
- International Entities: Any funds, equipment, or materials originating from or going to a foreign institution, entity, or individual.
- Sanctioned or Debarred Individuals or Entities: A donor or recipient who is subject to U.S. government restrictions or OFAC sanctions.
- Sanctioned Regions: Any connection to countries under U.S. sanctions (e.g., Russia, Iran, Cuba, North Korea).
- Restricting Terms: If the donor requires that certain nationalities be excluded from using the equipment or seeing the research results.
If your donation meets any of the high-risk criteria listed above, please reach out to the Office of Export Compliance at export@psu.edu so we can provide guidance on any applicable import or export requirements.
Next Steps: Routing Your Donation
Once you have cleared the export “Red Flags” above, follow either the receiving or giving workflow process.
If you are RECEIVING a donation, there are two workflows: 1)”Gifts” or 2) “Sponsored Research”
- Gifts: Refer to the OSP Gifts and Charitable Contributions page.
- Sponsored Research: Use Policy RA04 to determine if your funding should be handled by University Development or the Office of Sponsored Programs (OSP).
If you are GIVING away University equipment:
University property belongs to the University and cannot be given directly to outside individuals or organizations per University Policy FN14. Contact the Office of Budget and Finance, Asset Management to ensure the item is properly removed from the University ledger.
Office for Research Protections
Address
200 Innovation Blvd.
Suite 110
University Park, PA 16802
The Office for Research Protections (ORP) ensures that research at the University is conducted in accordance with federal, state, and local regulations and guidelines that protect human participants, animals, students, and personnel involved with research.