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The Export Administration Regulations (EAR) are implemented by the Bureau of Industry and Security (BIS) within the Department of Commerce. The EAR regulates the export of “dual use” goods and services (goods and services having both military and civilian uses) that are identified on the Commerce Control List (CCL). These are items that are not inherently military in nature; they are primarily commercial items with potential military uses.

The International Traffic in Arms Regulations (ITAR) are implemented by the State Department’s Directorate of Defense Trade Controls (DDTC). These regulations apply to articles, services, and related technical data that are inherently military in nature, as determined by the State Department. These “defense articles,” "defense services,” and related “technical data” are listed on the U.S. Munitions List (USML). Some articles and technologies that are not readily identifiable as inherently military in nature—for example, research satellites or small, research submersibles—are included on the USML.

The Treasury Department’s Office of Foreign Assets Control (OFAC) implements the economic and trade sanctions and, based on U.S. foreign policy and national security goals, targets foreign countries, terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of weapons of mass destruction. The university typically encounters issues arising under the OFAC regulations when researchers engage in collaborations with foreign nationals overseas or seek to teach classes or perform research in foreign countries.

The Office of Institutional Ethics and Compliance (OIEC) is committed to providing guidance and training to facilitate compliance with export control requirements, monitoring the transactions and relationships between UMass Dartmouth and foreign entities to ensure that export control regulations are met, and managing any export control related issues that may arise.

UMass Dartmouth policy requires all employees, visiting scientists, postdocs, and students working at or for UMass Dartmouth to comply with U.S. laws and regulations, including compliance with U.S. export controls applicable to the university’s operations. Export controls are a complex and ever-changing set of laws and regulations that can impact the university in myriad ways. It is critical export control requirements are complied with to prevent serious civil and/or criminal penalties for both the employee and the institution. In addition, note, export controls can be triggered by providing certain services to sanctioned countries, entities, or persons, or providing certain defense-related services to foreign entities or persons.

All UMass Dartmouth employees with managerial or supervisory authority over foreign nationals, or with projects involving materials or technology subject to export controls, should view export-control compliance as an important part of their day-to-day responsibilities.
For further assistance, or if you have any questions, please contact Stephanie Pena, the Director of Institutional Ethics & Compliance via email at spena4@umassd.edu.
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