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Online Education Guidance during the COVID-19 Pandemic  

U.S.  Export Controls and Economic Sanctions – What to Look For

As the scope of JHU’s online education offerings expands, it is critical to review our compliance obligations under U.S. laws, known as “Export Controls” and “Economic Sanctions.” These laws and regulations include restrictions on JHU’s ability to provide services in certain countries and to certain persons, including online education. Therefore, please review the below scenarios and if any of these apply to your online education activities, please contact JHU’s Export Control & Facility Security Office (“ECO” below; office email address: ECO@jhu.edu) immediately:

  • A student, regardless of citizenship, is expected to receive online instruction while residing in any of the following countries or regions: Cuba, Iran, North Korea, Syria, or Ukraine (Crimea region only) (collectively referred to below as the “Comprehensively Sanctioned Countries”).
  • A student, who is a citizen of a Comprehensively Sanctioned Country, holds a non-immigrant visa (F-1, J-1, etc.), and is expected to receive online instruction while outside the United States (i.e., in any country).
  • Any foreign student, who does not hold a non-immigrant visa, who is a citizen of a Comprehensively Sanctioned Country or of a Targeted-Sanction Country is expected to receive online instruction from any location (including the United States).
  • A student’s access to an online course from another country has been blocked. ***Pending investigation by ECO, please do not try to work around the blocked access ***

NOTE: We recognize that, in some cases, it may not be readily known if one or more of the above scenarios applies to your course. The expectation is that you make a reasonable effort to screen for them.

Restrictions Applied by Other Countries

Some countries ordinarily will require that JHU register as a provider of online services to those within their borders and/or to pay taxes on income derived from such services. Due to the pandemic, some countries have relaxed these and other requirements. However, please note that another country’s decision to relax their local laws does not alter JHU’s obligation to comply with US laws, including export controls and economic sanctions. If you have questions about how any particular country’s laws might apply to your course, please contact the JHU Office of General Counsel (OGC) for assistance.

Any Further Questions?

Please access additional information about these U.S. and foreign online education compliance issues at JHU’s Frequently Asked Questions (FAQs).

For your reference, please follow this link to access the Online Education Checklist, which you can use as a template to consider the multiple domestic and foreign compliance issues that might apply to your distance-learning activities.

 

 

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