Export Controls Management Plan
Commitment to Export Controls Compliance
It is the policy of the University to comply with all laws applicable to research including export controls regulations.
University Export Controls Committee
Members of the University Export Controls Committee include representatives from academic and administrative units throughout the University.
University Employees Responsible for Export Control Compliance
The current director of the Office of Trade Compliance will function as the University’s primary Empowered Official for export controls matter. The Empowered Officials have the authority to resolve export controls matters within their area of operation and represent the University before the export controls regulators in matters related to registration, licensing, commodity jurisdiction requests, or voluntary disclosures.
Acknowledgements & Technology Control Plans (TCPS)
If the UECO determines a certain item, technology, visit or specific project is export controlled, the UECO and export control staff will work with the PI to develop and implement a Technology Control Plan (TCP) to secure the controlled technology from access by unlicensed non-U.S. citizens.
Licensing
If an export license is needed for either an export or deemed export for University sponsored operations, the UECO shall have primary responsibility for preparing and submitting such license requests to the appropriate government agency for consideration.
License Exceptions & Exemptions Related to Travel Outside the U.S.
A license exception or exemption from license requirements may exist for travel or transmissions to destinations outside the U.S., depending on which items are taken, which countries are visited, and what activities are planned.
Training Programs
Training is the foundation of a successful export compliance program. Well-informed faculty and staff minimize the likelihood that inadvertent violations of the law will occur.
Recordkeeping
Unless otherwise provided for, all records indicated herein shall be maintained consistent with the University’s record retention policy, and shall be retained no less than five years after the project’s TCP termination date or license termination date, whichever is later.
Monitoring & Auditing
In order to maintain the University’s export compliance program and to ensure consistent adherence to U.S. export laws and regulations, the UECO may conduct internal reviews of certain processes and records.
Detecting & Reporting Violations
Since September 11, 2001, government agencies have dramatically increased the investigation in and successful prosecution of export regulation violations. The penalties for these violations can be very severe, including personal liability, monetary fines, and imprisonment.
Compliance with Policy
In recognition of the seriousness of non-compliance with export controls, the University may address non-compliance with employee discipline including termination of employment in accordance with existing University policies and procedures.