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Export Control Compliance Policy

Policy Number ACA-C10-003
Effective Date November 22, 2010
Responsible Office/Person Office of Institutional Compliance
Related Policies
Additional History
Additional References

UML Export Control Guidelines

UML Export Control SOP

I.            Policy

The University of Massachusetts Dartmouth Policy on Export Control is to comply fully with the U.S. Export Control Laws and trade sanctions laws and regulations.

II.           Purpose

It is the mission and policy of the University of Massachusetts Dartmouth to conduct instruction and research openly and without prohibitions on the dissemination of learning or research activities. As a result, in most instances the requirements of the U.S. export control laws can be appropriately satisfied through reliance on available exclusions from export controls, such as exclusions for educational information, and information that is publicly available or in the public domain.

Export controls and trade sanctions are the United States laws and regulations that regulate and restrict the release of critical technology, software, equipment, chemical, biological materials and other materials, and services to foreign nations and foreign countries for reasons of foreign policy and national security.

These laws apply to virtually all fields of science and engineering and restrict the shipment, transmission or transfer of certain commodities, software, technology and services from the U.S. to foreign countries. Deemed exports, i.e. the release of controlled information to foreign nationals located in the U.S., are also restricted under these laws and regulations. Export control laws apply to all activities – not just sponsored research projects.

III.         Definitions

The U.S. Government agencies have primary export control regulatory responsibilities. The Department of Commerce through its Export Administration Regulations (EAR), the State Department through its International Traffic in Arms Regulations (ITAR) and the Arms Export Control Act (AECA), and the Treasury Department through the Office of Foreign Assets Control (OFAC) administer the export control laws and trade sanctions. The Commerce Department administers the Commerce Control List (CCL) and the State Department administers the U.S. Munitions List (USML)

An export is:

  • Shipment of a controlled commodity, equipment, material, or software outside the U.S.;
  • Disclosing controlled technology or technical data to a foreign national, whether in the U.S. or abroad;
  • Performing technical assistance or defense services for or on behalf of a foreign national, whether in the U.S. or abroad;
  • Exports within the U.S. are considered to be a “deemed” export to the foreign national’s home country.

IV.          Procedures

Faculty, administrators, and staff are expected to contact the Office of Institutional Compliance should they have any questions about the application of U.S. Exports controls or trade sanctions to their research or other activities.  The procedures and guidelines on export control are more fully outlined at http://www.atmc.umassd.edu/institutional_compliance/export.cfm. The Office of Institutional Compliance will determine if exemptions or exclusions apply, or if a license is required. The Office of Institutional Compliance will make available export control training to faculty, administrators, and staff.  Faculty, administrators, and staff should report any potential violations to the Office of Institutional Compliance.

V.            Responsibility

The Office of Institutional Compliance is responsible for developing and implementing an export control program.  The Office of Institutional Compliance ensures that faculty, administrators, and staff comply with University export control procedures and guidelines, and federal export control regulations.

VI.           Attachments

                Export Compliance Standard Operating Procedures
                Export Control Compliance Guidelines

VII.         Approval and Effective Date

Effective Date: November 22, 2010

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