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Export Controls > Research > Bona fide Employee Exemption


Bona fide Employee Exemption (limited use for Cornell faculty)

The ITAR (U.S. 22 CFR §125.4 (b)(10)) authorizes the transfer of unclassified technical data by U.S. institutions of higher learning to foreign persons in the United States who are bona fide, full-time regular employees of that institution.  Three criteria are required:

  1. The employees’ permanent abode throughout the period of employment be in the United States.
  2. The employee can NOT be listed as a national of a country listed in 126.1 of the ITAR.
  3. The employee is notified in writing that the technical data may not be transferred to other foreign persons with the prior written approval of the Department of State.