Deemed Exports
A “deemed export” is the transfer or release of controlled material or technology to a foreign national within the United States. Exposing a non-U.S. person to controlled materials is considered the same as exporting directly to that person’s home country. Controlled materials are not only tangible items like research equipment, biological agents, or chemicals, but also include intangibles such as data, information, and encryption. Additionally, the methods of transfer vary and can involve sending an email, allowing visual inspection, engaging in a phone conversation, or providing demonstrations or training. Such disclosures, if made without an authorized license from the appropriate U.S. Government agency, are potentially in violation of export laws and could result in harsh penalties.
What Does This Mean for Vanderbilt?
Vanderbilt University is committed to maintaining an open and free academic environment that supports international collaboration. However, federal regulations require Vanderbilt to evaluate the potential for deemed exports, determine if an export license is needed, and certify these findings. The Visa Deemed Export Questionnaire (VDEQ) fulfills Vanderbilt’s compliance requirement and helps Vanderbilt’s Export Compliance (VEC) program determine if an export license is necessary. It also allows VEC to assist faculty and departments in developing best practices and addressing concerns.
Who Is Required to Complete a VDEQ?
As part of our dedication to protecting Vanderbilt’s innovative research, VEC advises faculty and staff submit a VDEQ for the following individuals, so we can evaluate deemed export concerns prior to their arrival:
| Required | Not Required |
|---|---|
| All employment visas (H1B, O1, EAD, etc.) | Students |
| All J1 visas | Permanent Residents |
| Asylum Refugees |
If you are sponsoring one of these visa types, please complete the Visa Deemed Export Questionnaire (VDEQ) to assist with export compliance analysis. Allow a minimum of five (5) business days for review. Contact vec@vanderbilt.edu with any questions or concerns you may have.