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.
Note that information which meets the criteria of being in the public domain, being educational information, or resulting from Fundamental Research is not subject to export controls under the EAR or the ITAR. Therefore, the special requirement for recordkeeping when using a valid exclusion will not apply. However, it is a good practice to provide such description for each project to establish a record of compliance.
BIS has specific record-keeping requirements. Under the EAR, records are required to be kept for a period of five years from the project’s termination date. However, if BIS or any other government agency makes a request for such records following a voluntary self-disclosure, the records must be maintained until the agency concerned provides written authorization otherwise. Recordkeeping is important and is currently being done in multiple University systems through a combination of hard copy and electronic files.