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Responsible Conduct in Research: Export Controls |
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"Export Controls" is a term used to refer to a set of federal regulations that restrict when we can send certain items overseas or share technology with foreign nationals in the U.S. The regulations are both lengthy and complex. Anyone in the UNCW community is encouraged to contact Leanne Prete, regulatory compliance officer with any questions or concerns. Contents: UNCW Policy and Procedures Software Licensing Links Title: What You Need to Know About Export Controls Leanne Prete, Regulatory Compliance Officer, 910-962-7774 or pretel@uncw.edu Dr. Bob Roer, Export Control Empowered Official, 910-962-4117, roer@uncw.edu Export Compliance Policy, approved October 1, 2007 DRAFT Export Control Management Plan, revised October 15, 2007 UNCW Export Controls - Basic Questions and Answers - For anyone new to export controls. UNCW Interactive Learning Tool for Export Controls - Everything you never wanted to know about export controls in an interactive powerpoint slide show. Explains when the fundamental research exclusion applies, what a foreign national is, and license exceptions for traveling with laptops and GPS. UNCW Question and Answer Excerpts from the Export Administration Regulations - This document contains numerous scenarios that are very relevant to university activities. UNCW Helpful Excerpts from the Export Administration Regulations Regarding Research - Defines the fundamental research and educational information exclusions. UNCW Export Controls Decision Tree - see if you are subject to the Export Administration Regulations and if so, if you need to apply for a license. You may also be interested in the U.S. Department of Commerce Bureau of Industry and Security Decision Tree (see Agency Resources Section below). Please note - neither this decision tree nor the BIS tree applies to exports covered under the International Traffice in Arms Act (ITAR).
What to Do if You are Traveling Outside the U.S. with a Laptop Traveling outside the continental US on university business? Teaching a class overseas? If you plan to bring a laptop, you will be subject to the export control regulations. Laptops themselves are not very strictly controlled, but software installed on the laptops that has encryption capabilities is very tightly controlled. However, there are a few options to remain in compliance with the regulations when you plan to travel with a laptop. First, if you personally own the laptop you are eligible for the "baggage" license exception to the Export Administration Regulations. There are certain conditions that must be met, so please contact the regulatory compliance officer in ORSSP (pretel@uncw.edu, 962-7774) for more information about this license exception. Second, if the university owns the laptop, you may be eligible for the "temporary export" license exception if you are able to meet certain conditions. Most are easy to meet except that you must maintain "effective control" of the laptop, which means it must be in your possession at all times or you must keep it in a locked hotel safe. The Bureau of Industry and Security does not consider a locked hotel room to consitute "effective control". Please contact the regulatory compliance officer in ORSSP (pretel@uncw.edu, 962-7774) for more information about this license exception. If the two license exceptions above do not work for you, you may want to consider checking out a laptop through the ITSD Faculty and Staff Laptop Checkout Program. These laptops are installed only with software that is already under license by the manufacturer for exporting. Laptops can be checked out for an entire semester if needed. For more information about this program please contact the Technology Assistance Center at 910.962.4357, tac@uncw.edu. If you are interested in finding out more about software that is under license for exporting, here are links to some of the companies we use most frequently: Adobe Product Export Information Symantec Export Control Classifications
There are three federal agencies involved in administering the export control regulations: the Department of Commerce, the Department of the Treasury and the Department of State. Below are links to these agencies. U.S. Department of Commerce - Bureau of Industry and Security: Responsible for implementing and enforcing the Export Administration Regulations or EAR, which regulate the export and reexport of most commercial items. U.S. Department of the Treasury - Office of Foreign Assets Control (OFAC): Administers and enforces economic and trade sanctions based on US foreign policy and national security goals. U.S. Department of State - International Traffic in Arms Regulations (ITAR): Responsible for the control of the permanent and temporary export and temporary import of defense articles and services. Here are links to export control websites for some of the larger institutions that have excellent export control resources and information. Chapel Hill's Export Control Webpage NCSU's Export Controls Webpage Stanford's Export Control Decision Tree
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