Training Program
The training program is a critical component of maintaining compliance and increasing awareness of export control and trade sanction laws. The program educates the UMassD community about its responsibilities under these laws and procedures in place for ensuring compliance. It is especially critical that faculty administrative staff, students who direct or participate in research projects involving export-controlled goods, technology or software.
Training can include an overview of the purpose of export controls, how export regulations apply to different activities, review of definitions and regulations, the importance of compliance, description of the high-risk disciplines, and the types of exclusions, exemptions and exceptions that commonly apply. In addition, training can cover security measures that should be followed, steps to follow for physical exports, instruction on how to determine the CCL or USML designation of items, information about applying for a license, identification and reporting export control violations and red flags, internal review procedures, the importance of training, and the importance of utilizing the OIEC as a resource.
The following introductory topics are among those covered in faculty, staff, and student training:
- Purpose of U.S. export control laws and regulatory agencies controlling exports;
- What is an Export and What Regulations Apply; Physical Exports and Deemed Exports;
- U.S. Munitions List and Commerce Control List;
- General Prohibitions on End Use and End Users;
- Restricted Party Screening Using Lists of Denied and Restricted Persons and Countries;
- How to detect and report suspicious and inconsistent behavior and/or activities (red flags);
- Protection of intellectual property / elicitation techniques;
- Office of Foreign Asset Control Sanctions & Embargoes;
- Fundamental research and education/employment exclusions;
- International Visitors;
- Examples of common license exemptions;
- Enforcement of violations and the severity of penalties and sanctions which can apply;
- Contact Persons for Further Assistance; FAQs; Questions and Answers.
Advanced training topics for faculty and administrative staff include:
- Contract language that restricts publication and personnel access;
- Foreign sponsorship of research;
- Nondisclosure agreements with foreign entities or persons;
- Materials transfer agreements with foreign entities or persons;
- Teaching or training activities that use or implement licensed technology;
- Activities involving export-controlled information furnished to/at UMassD;
- Foreign national students working in high-risk disciplines (such as engineering and science).
- Foreign Corrupt Practices Act (for faculty assigned to teach oversees)
- Technology Control Plans
The OIEC customizes training to the needs and concerns of departments in high-risk disciplines such as Engineering, Physics, Computer Science, Marine Sciences, and research with encrypted software, controlled chemicals, select agents, and toxins. The OIEC can schedules training upon request to maximize outreach. The OIEC uses a PowerPoint presentation to introduce training with opportunities for questions and discussion. Also, OIEC provides additional information and regulatory updates in the form of email notifications, institutional compliance newsletters, and invited speakers.
One-on-one training can be provided by OIEC to researchers who are involved in projects confirmed to involve export-controlled technology. The type of training, date, and who was trained is recorded and kept on file with the OIEC. While most training will be classroom style with opportunity for questions and discussion, additional information may be provided in the form of email notifications, institutional compliance newsletters and announcements, online training and information, and invited speakers. Useful materials and forms are available on the OIEC website.
Online training is available here.