Export Controls and Compliance in Universities
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Export Control Basics
Export Control Basics
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System Policy – 15.02
•
System Policy 15.02 –
Export Controls
–
Adopted 2009, Re-certified 2012.
•
Policy Statement
–
The Texas A&M University System (system), its members,
employees and students must comply with all United States
export control laws and regulations, including those implemented
by the Department of Commerce through its Export
Administration Regulations (EAR) and the Department of State
through its International Traffic in Arms Regulations (ITAR), as
well as those imposed by the Treasury Department through its
Office of Foreign Assets Control (OFAC).
2
What are “Export Controls?”
•
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•
Export control laws apply to all activities –
not just research projects.
3
Why do we have Export Controls?
o
Advance foreign policy goals;
o
Restrict export of goods and technology
that might contribute to the military
expertise of adversaries;
o
Prevent the proliferation of WMD;
o
Fulfill international obligations (e.g.,
treaties); and
o
Prevent terrorism.
4
Why should Universities be concerned?
9/11 changed everything:
•
There is a growing
intersection of cutting
edge research with
national security and
foreign policy.
•
Many foreign students
seek educations from
U.S. universities.
5
•
Universities have become a
focal point for export control
compliance.
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6
Export Control Compliance
To have an effective compliance program,
an organization must establish and
maintain an organizational culture that
“encourages ethical conduct and a
commitment to compliance with the law.”
U.S. Federal Sentencing Guidelines
§8B2.1(a)(2)
7
Federal Sentencing Guidelines
–
Establish a culture of compliance
–
Identify and assess the risks
–
Develop written policies and procedures to
address the risk
–
Provide training and education
–
Keep lines of communication open
–
Monitor compliance
–
Respond to instances of noncompliance
8
What does this mean?
•
System Policy 15.02 requires system
members to:
–
Understand the regulatory framework
–
Appoint an “Empowered Official”
–
Adopt a rule for export control compliance
–
Develop procedures to address the risk
9
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10
Keys to Understanding Export Controls
•
Who?
•
What?
•
When?
•
Where?
•
Why?
•
How?
11
WHO regulates export controls?
Three federal agencies govern U.S. export
controls:
12
U.S. State Department
U.S. Department of Commerce
U.S. Treasury Department
U.S. State Department
•
Directorate of Defense Trade Controls
(DDTC)
o
Arms Export Control Act of 1976, 22 U.S.C.
§2778
o
International Traffic in Arms Regulations
(ITAR), 22 C.F.R., Part 120
o
US Munitions List, 22 C.F.R., Part 121
13
About the ITAR
•
Covers military items, e.g., munitions, “defense articles” or “defense
services.”
•
Regulates goods and technology designed to kill people or defend
against death in a military setting.
•
“Defense articles” include technical data, which encompasses
software, furnishing assistance such as design, engineering and use
of defense articles.
•
“Defense services” include the transfer of information, even if in the
public domain.
•
Also includes space-related technology and research; increasing
applicability to other research areas such as nanotechnology, new
materials, sensors and life sciences.
14
U.S. Department of Commerce
•
Bureau of Industry and Security (BIS)
o
Export Administration Act of 1979, 50 U.S.C.
§§2401-20
o
Export Administration Regulations (EAR), 15
C.F.R., Parts 730-74
o
Commerce Control List, Supplement No. 1 to
Part 774 of the EAR
15
About the EAR
•
Covers dual-use items, or items designed for a
commercial purpose that might also have a military
application, e.g., computers, pathogens, civilian aircraft.
•
10 categories of different technologies on the Commerce
Control List (CCL).
•
Covers goods, test equipment, materials, technology,
including technical data and assistance, and software.
•
Also covers “re-export” of U.S. origin items outside the
U.S.
16
U.S. Treasury Department
•
Office of Foreign Asset Control (OFAC)
o
Trade Sanctions & Embargoes – prohibitions
on trade with certain countries, e.g., Iran,
Syria, Sudan, Cuba, North Korea.
o
Restrictions on financial transactions or
transfers to certain end-users.
17
NEW Embargoes and Sanctions
•
Iran Threat Reduction and Syrian Human Rights
Act of 2012 (ITRA)
•
Signed into law on August 10, 2012
•
Prohibits foreign subsidiaries of U.S. companies from
engaging in transactions that a U.S. company cannot
engage in.
•
Implements visa restrictions for Iranian citizens
seeking higher education in the “energy, nuclear
science, nuclear engineering or related fields.”
18
WHO is a “Foreign Person?”
•
For export control purposes a “foreign person”
includes:
–
Persons in the U.S. in non-immigrant status (e.g., H-
1B, H-3, L-1, J-1, F-1 Practical Training, L-1)
–
Persons unlawfully in the U.S.
•
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e
:
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U.S. Citizens
–
Permanent Residents (i.e., green card holders)
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Persons granted asylum or refugee status
19
WHAT is an Export?
20
Any item, technology, or software that is sent from
the United States to a foreign destination:
•
E-mail, phone, mail, travel, package, conference
presentation, face-to-face, visual inspection, hand
carried items – laptop, memory devices
Exports in a University Setting
These items may include:
•
Unpublished research findings
•
Funds that are transferred to restricted countries,
entities or persons
•
Biological specimens
•
Chemicals
•
Electronics
•
Computers
•
Sensors
21
WHAT is a “deemed export?”
•
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This type of export may include:
–
Visual inspection by foreign persons of U.S.-origin equipment
and facilities;
–
Oral exchanges of information; or
–
Access to a computer that possesses export controlled
information/technology.
22
WHEN should I be concerned about
export controls?
•
N
O
W
–
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.
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:
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Student Enrollment
–
Employee Hiring
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Research
–
Purchasing
–
Travel
–
Shipping
23
WHERE do I look for guidance?
•
Y
o
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o
N
O
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-
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•
You just need to find
the wheel that fits.
•
R
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m
b
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r
:
O
n
e
s
i
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e
d
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N
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fit all!
24
Export Control Resources
F
e
d
e
r
a
l
A
g
e
n
c
y
W
e
b
s
i
t
e
s
:
•
U.S. Department of Commerce, Bureau of Industry and Security (BIS)
http://www.bis.doc.gov/index.htm
–
Export Management and Compliance Program (EMCP)
–
BIS Compliance Guidelines: How to Develop an Effective Export management and Compliance Program
and Manual (166 pages)
–
BIS Seminars and Training
•
U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
http://www.pmddtc.state.gov/index.html
•
U.S. Department of Treasury, Office of Foreign Asset Control (OFAC)
http://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-
Foreign-Assets-Control.aspx
25
Export Control Resources (cont.)
•
Higher Education Compliance Alliance
–
http://www.higheredcompliance.org/
•
University Websites:
–
Texas A&M University
http://vpr.tamu.edu/resources/export-controls/resources
–
Stanford University
http://export.stanford.edu/
–
University of Texas – Austin
http://www.utexas.edu/research/osp/export_control/
–
University of Tennessee – Knoxville
http://research.utk.edu/exportcontrol/
–
University of South Florida
http://www.research.usf.edu/dsr/export-controls/export-controls.asp
26
WHY do I Need to Comply with
Export Control Regulations?
•
I
t
’
s
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l
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w
!
•
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o
r
p
o
r
a
t
i
o
n
s
.
–
Up to $1MM for institutions/corporations and up to $250,000
for individuals
–
Up to 10 years in prison
–
Termination of export privileges
–
Suspension and/or debarment
from federal government contracting
–
Loss of federal funds
Recent Enforcement Actions
•
Dr. J. Reece Roth, University of Tennessee –
charged with 15 counts of violating the Arms Export
Control Act; sentenced to 4 years in prison
•
Dr. Thomas Butler, Texas Tech – indicted on 69
counts; sentenced to 2 years in prison for making
fraudulent claims and unauthorized exports (plague
bacteria)
•
UMass, Lowell – BIS imposed $100,000 penalty,
suspended for illegal exports to SUPARCO, a
Pakistani entity listed on the Denied Parties List
•
NYU – Scientists arrested for selling MRI
technology developed through federal research
funding to Chinese government
28
HOW do I get started?
•
THREE steps towards
compliance:
1.
Appoint an Empowered
Official
2.
Adopt a rule
3.
Develop procedures to
address the risks
29
Appointing an Empowered Official
•
The Empowered Official is responsible for
export control compliance and oversight
for your agency or campus.
–
They must be knowledgeable of the
regulations (or, at a minimum, trainable);
–
They must be aware of your agency/campus
activities; and
–
They must have authority to stop any activity
that may result in a violation of law.
30
11/12
Adopting a Rule
•
What should be included?
–
The position title of your Empowered Official (e.g.,
Vice President for Research, Compliance Officer,
CFO, etc.)
–
Descriptions of how your agency/campus will handle
potential export control risks and contact office (e.g.
Restricted Party Screening; travel or shipping
requests; research grants/contracts etc.)
•
Less is More!
31
11/12
Developing Procedures to Address Risks
•
Review Processes
–
Travel
•
Who is going? Where? AND what are they taking?
–
Shipping
•
In-House v. Third Party (UPS, Fed-Ex, etc.)
•
Screening Procedures
–
Visual Compliance
•
Technology Control Plans
–
Equipment
–
Research Projects
32
11/12
WHERE do I look for guidance?
•
Y
o
u
d
o
N
O
T
n
e
e
d
t
o
r
e
-
i
n
v
e
n
t
t
h
e
w
h
e
e
l
.
•
You just need to find
the wheel that fits.
•
R
e
m
e
m
b
e
r
:
O
n
e
s
i
z
e
d
o
e
s
N
O
T
fit all!
33
11/12
Export Control Resources
S
y
s
t
e
m
R
e
s
o
u
r
c
e
s
:
•
System Offices
–
System Ethics and Compliance Officer
–
Office of General Counsel
•
Texas A&M University
http://vpr.tamu.edu/resources/export-controls/resources
•
Texas A&M University – Corpus Christi
http://research.tamucc.edu/compliance/export.html
•
TEES
http://tees.tamu.edu/researchcompliance/export-controls/
•
SRS
http://osrs.tamus.edu/contracts-and-grants/project-administration/compliance/
34
11/12
Export Control Resources (cont’d)
F
e
d
e
r
a
l
A
g
e
n
c
y
W
e
b
s
i
t
e
s
:
•
U.S. Department of Commerce, Bureau of Industry and Security (BIS)
http://www.bis.doc.gov/index.htm
–
Export Management and Compliance Program (EMCP)
–
BIS Compliance Guidelines: How to Develop an Effective Export Management
and Compliance Program and Manual (166 pages)
–
BIS Seminars and Training
•
U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
http://www.pmddtc.state.gov/index.html
•
U.S. Department of Treasury, Office of Foreign Asset Control (OFAC)
http://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-
Foreign-Assets-Control.aspx
35
11/12
Export Control Resources (cont’d)
•
Higher Education Compliance Alliance
http://www.higheredcompliance.org/
•
Other University Websites:
–
Stanford University
http://export.stanford.edu/
–
University of Texas – Austin
http://www.utexas.edu/research/osp/export_control/
–
University of Tennessee – Knoxville
http://research.utk.edu/exportcontrol/
–
University of South Florida
http://www.research.usf.edu/dsr/export-controls/export-controls.asp
–
Wayne State University
http://research.wayne.edu/export-control/
36
11/12
Contact Information
•
System Ethics &
Compliance Officer
Janet Smalley
janetsmalley@tamus.edu
(979) 458-6008
•
Texas A&M University
Brad Krugel
bkrugel@tamu.edu
(979) 862-6419
37
11/12
•
Texas A&M University –
Corpus Christi
Erin Sherman
erin.sherman@tamucc.edu
(361) 825-2497
•
TEES
Sean Rubino
srubino@tamu.edu
(979) 458-7652
Questions?
38
11/12
Export controls are crucial regulations governing the export of strategic technologies, equipment, and software, aiming to advance foreign policy goals, prevent the proliferation of weapons of mass destruction, and counter terrorism. The Texas A&M University System emphasizes compliance with U.S. export control laws and regulations, reflecting the importance of developing a strong compliance program in educational institutions post-9/11. To effectively navigate these regulations, organizations must establish a culture of ethical conduct and a commitment to compliance.
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Presentation Transcript
Export Control Basics Kristen Worman Assistant General Counsel kworman@tamus.edu (979) 458-6124
System Policy 15.02 System Policy 15.02 Export Controls Adopted 2009, Re-certified 2012. Policy Statement The Texas A&M University System (system), its members, employees and students must comply with all United States export control laws and regulations, including those implemented by the Department of Commerce through its Export Administration Regulations (EAR) and the Department of State through its International Traffic in Arms Regulations (ITAR), as well as those imposed by the Treasury Department through its Office of Foreign Assets Control (OFAC). 2
What are Export Controls? Export Controls are U.S. government regulations that govern the export of strategic technologies, equipment, hardware, software or providing technical assistance to Foreign Persons. Export control laws apply to all activities not just research projects. 3
Why do we have Export Controls? oAdvance foreign policy goals; oRestrict export of goods and technology that might contribute to the military expertise of adversaries; oPrevent the proliferation of WMD; oFulfill international obligations (e.g., treaties); and oPrevent terrorism. 4
Why should Universities be concerned? 9/11 changed everything: There is a growing intersection of cutting edge research with national security and foreign policy. Universities have become a focal point for export control compliance. Many foreign students seek educations from U.S. universities. 5
Export Control Compliance To have an effective compliance program, an organization must establish and maintain an organizational culture that encourages ethical conduct and a commitment to compliance with the law. U.S. Federal Sentencing Guidelines 8B2.1(a)(2) 7
Federal Sentencing Guidelines Establish a culture of compliance Identify and assess the risks Develop written policies and procedures to address the risk Provide training and education Keep lines of communication open Monitor compliance Respond to instances of noncompliance 8
What does this mean? System Policy 15.02 requires system members to: Understand the regulatory framework Appoint an Empowered Official Adopt a rule for export control compliance Develop procedures to address the risk 9
Keys to Understanding Export Controls Who? What? When? Where? Why? How? 11
WHO regulates export controls? Three federal agencies govern U.S. export controls: US_Department_of_State U.S. State Department U.S. Department of Commerce treasury-1 U.S. Treasury Department 12
U.S. State Department Directorate of Defense Trade Controls (DDTC) o Arms Export Control Act of 1976, 22 U.S.C. 2778 o International Traffic in Arms Regulations (ITAR), 22 C.F.R., Part 120 o US Munitions List, 22 C.F.R., Part 121 13
About the ITAR Covers military items, e.g., munitions, defense articles or defense services. Regulates goods and technology designed to kill people or defend against death in a military setting. Defense articles include technical data, which encompasses software, furnishing assistance such as design, engineering and use of defense articles. Defense services include the transfer of information, even if in the public domain. Also includes space-related technology and research; increasing applicability to other research areas such as nanotechnology, new materials, sensors and life sciences. 14
U.S. Department of Commerce Bureau of Industry and Security (BIS) o Export Administration Act of 1979, 50 U.S.C. 2401-20 o Export Administration Regulations (EAR), 15 C.F.R., Parts 730-74 o Commerce Control List, Supplement No. 1 to Part 774 of the EAR 15
About the EAR Covers dual-use items, or items designed for a commercial purpose that might also have a military application, e.g., computers, pathogens, civilian aircraft. 10 categories of different technologies on the Commerce Control List (CCL). Covers goods, test equipment, materials, technology, including technical data and assistance, and software. Also covers re-export of U.S. origin items outside the U.S. 16
U.S. Treasury Department Office of Foreign Asset Control (OFAC) o Trade Sanctions & Embargoes prohibitions on trade with certain countries, e.g., Iran, Syria, Sudan, Cuba, North Korea. o Restrictions on financial transactions or transfers to certain end-users. 17
NEW Embargoes and Sanctions Iran Threat Reduction and Syrian Human Rights Act of 2012 (ITRA) Signed into law on August 10, 2012 Prohibits foreign subsidiaries of U.S. companies from engaging in transactions that a U.S. company cannot engage in. Implements visa restrictions for Iranian citizens seeking higher education in the energy, nuclear science, nuclear engineering or related fields. 18
WHO is a Foreign Person? For export control purposes a foreign person includes: Persons in the U.S. in non-immigrant status (e.g., H- 1B, H-3, L-1, J-1, F-1 Practical Training, L-1) Persons unlawfully in the U.S. It does NOT include: U.S. Citizens Permanent Residents (i.e., green card holders) Persons granted asylum or refugee status 19
WHAT is an Export? Any item, technology, or software that is sent from the United States to a foreign destination: E-mail, phone, mail, travel, package, conference presentation, face-to-face, visual inspection, hand carried items laptop, memory devices 20
Exports in a University Setting These items may include: Unpublished research findings Funds that are transferred to restricted countries, entities or persons Biological specimens Chemicals Electronics Computers Sensors 21
WHAT is a deemed export? A deemed export is the release of controlled information, technology or software to a foreign person in the United States. The regulations deem this transfer of information, technology or software to be an export to the home country of the foreign person. This type of export may include: Visual inspection by foreign persons of U.S.-origin equipment and facilities; Oral exchanges of information; or Access to a computer that possesses export controlled information/technology. 22
WHEN should I be concerned about export controls? NOW U.S. export control regulations affect many activities on university campuses, including: Student Enrollment Employee Hiring Research Purchasing Travel Shipping 23
WHERE do I look for guidance? You do NOT need to re-invent the wheel You just need to find the wheel that fits. Remember: One size does NOT fit all! 24
Export Control Resources Federal Agency Websites: U.S. Department of Commerce, Bureau of Industry and Security (BIS) http://www.bis.doc.gov/index.htm Export Management and Compliance Program (EMCP) BIS Compliance Guidelines: How to Develop an Effective Export management and Compliance Program and Manual (166 pages) BIS Seminars and Training U.S. Department of State, Directorate of Defense Trade Controls (DDTC) http://www.pmddtc.state.gov/index.html U.S. Department of Treasury, Office of Foreign Asset Control (OFAC) http://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of- Foreign-Assets-Control.aspx 25
Export Control Resources (cont.) Higher Education Compliance Alliance http://www.higheredcompliance.org/ University Websites: Texas A&M University http://vpr.tamu.edu/resources/export-controls/resources Stanford University http://export.stanford.edu/ University of Texas Austin http://www.utexas.edu/research/osp/export_control/ University of Tennessee Knoxville http://research.utk.edu/exportcontrol/ University of South Florida http://www.research.usf.edu/dsr/export-controls/export-controls.asp 26
WHY do I Need to Comply with Export Control Regulations? It s the law! Severe criminal and civil noncompliance penalties and sanctions for individuals as well as institutions and corporations. Up to $1MM for institutions/corporations and up to $250,000 for individuals Up to 10 years in prison Termination of export privileges Suspension and/or debarment from federal government contracting Loss of federal funds
Recent Enforcement Actions Dr. J. Reece Roth, University of Tennessee charged with 15 counts of violating the Arms Export Control Act; sentenced to 4 years in prison Dr. Thomas Butler, Texas Tech indicted on 69 counts; sentenced to 2 years in prison for making fraudulent claims and unauthorized exports (plague bacteria) UMass, Lowell BIS imposed $100,000 penalty, suspended for illegal exports to SUPARCO, a Pakistani entity listed on the Denied Parties List NYU Scientists arrested for selling MRI technology developed through federal research funding to Chinese government 28
HOW do I get started? THREE steps towards compliance: 1. Appoint an Empowered Official 2. Adopt a rule 3. Develop procedures to address the risks 29
Appointing an Empowered Official The Empowered Official is responsible for export control compliance and oversight for your agency or campus. They must be knowledgeable of the regulations (or, at a minimum, trainable); They must be aware of your agency/campus activities; and They must have authority to stop any activity that may result in a violation of law. 11/12 30
Adopting a Rule What should be included? The position title of your Empowered Official (e.g., Vice President for Research, Compliance Officer, CFO, etc.) Descriptions of how your agency/campus will handle potential export control risks and contact office (e.g. Restricted Party Screening; travel or shipping requests; research grants/contracts etc.) Less is More! 11/12 31
Developing Procedures to Address Risks Review Processes Travel Who is going? Where? AND what are they taking? Shipping In-House v. Third Party (UPS, Fed-Ex, etc.) Screening Procedures Visual Compliance Technology Control Plans Equipment Research Projects 11/12 32
WHERE do I look for guidance? You do NOT need to re-invent the wheel. You just need to find the wheel that fits. Remember: One size does NOT fit all! 11/12 33
Export Control Resources System Resources: System Offices System Ethics and Compliance Officer Office of General Counsel Texas A&M University http://vpr.tamu.edu/resources/export-controls/resources Texas A&M University Corpus Christi http://research.tamucc.edu/compliance/export.html TEES http://tees.tamu.edu/researchcompliance/export-controls/ SRS http://osrs.tamus.edu/contracts-and-grants/project-administration/compliance/ 11/12 34
Export Control Resources (contd) Federal Agency Websites: U.S. Department of Commerce, Bureau of Industry and Security (BIS) http://www.bis.doc.gov/index.htm Export Management and Compliance Program (EMCP) BIS Compliance Guidelines: How to Develop an Effective Export Management and Compliance Program and Manual (166 pages) BIS Seminars and Training U.S. Department of State, Directorate of Defense Trade Controls (DDTC) http://www.pmddtc.state.gov/index.html U.S. Department of Treasury, Office of Foreign Asset Control (OFAC) http://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of- Foreign-Assets-Control.aspx 11/12 35
Export Control Resources (contd) Higher Education Compliance Alliance http://www.higheredcompliance.org/ Other University Websites: Stanford University http://export.stanford.edu/ University of Texas Austin http://www.utexas.edu/research/osp/export_control/ University of Tennessee Knoxville http://research.utk.edu/exportcontrol/ University of South Florida http://www.research.usf.edu/dsr/export-controls/export-controls.asp Wayne State University http://research.wayne.edu/export-control/ 11/12 36
Contact Information System Ethics & Compliance Officer Janet Smalley janetsmalley@tamus.edu (979) 458-6008 Texas A&M University Corpus Christi Erin Sherman erin.sherman@tamucc.edu (361) 825-2497 Texas A&M University Brad Krugel bkrugel@tamu.edu (979) 862-6419 TEES Sean Rubino srubino@tamu.edu (979) 458-7652 11/12 37
Questions? 11/12 38
