It is important to understand that export compliance is ultimately the responsibility of the individual with access to sensitive data or material. The ECO can provide assistance to all faculty/staff to help ensure compliance. The key is to know when to ask for help:
When do I need to contact the Export Control Office?
- I need to ship items internationally.
- I need to travel to Cuba, Iran, N. Korea, Syria, or Sudan.
- I want to collaborate with a researcher or an institution from outside the United States.
- My sponsor has requested that my research results be kept proprietary or has requested to review my results prior to publication.
- My sponsor has requested that only US persons work on the project, or, has requested the name and citizenship status of my researchers.
- I have received or need to receive export-controlled data from a sponsor, collaborator, or vendor.
- I have received or plan to receive hardware that the sponsor or vendor has designated “ITAR”.
- I have invented a new technology having an obvious military application.
- Provide training and customized guidance to researchers and administrators for all matters concerning export compliance.
- Perform Restricted Party Screenings (RPS) for visiting researchers, subcontractors, and other parties to confirm that the party has not been placed on any US or foreign lists denying them export privileges or access to US funds.
- Provide assistance with proposal development and negotiation with sponsors to provide “carve outs” for fundamental research.
- Provide assistance to international travelers to ensure compliance with export laws as well as sanctions against certain foreign locations.
- Assess technology, including software, for export control restrictions. This is required prior to sending any material out of the country, and in some cases, before providing foreign researchers access to data on campus.
- Apply for Department of State and Department of Commerce export licenses and Technical Assistance Agreements (TAAs) when required to support research activities.
- Provide risk assessments and up-to-date information on regulations and enforcement activities.
- Prepare and administer Technology Control Plans (TCPs) for researchers needing access to export controlled material or data.