Export Controls Marci Copeland Office of Research Export Control Administrator Agenda • Review: What Are Export Controls? • Program Updates • Questions Why is Awareness Important? • Maintain academic freedom of university environment • Violations can result in fines and/or jail sentences • National Security What are export control regulations? AGENCY: U.S. Department of State, Directorate of Defense Trade Controls (DDTC) Regulations: International Traffic in Arms Regulations (ITAR) U.S. Munitions List (USML) AGENCY: U.S. Department of Commerce, Bureau of Industry and Security (BIS) Regulations: Export Administration Regulations (EAR) Commerce Control List (CCL) Denied Persons List Entity List AGENCY: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) Sanctions programs Specially Designated Nationals List AGENCY: U.S. Department of State, Directorate of Defense Trade Controls (DDTC) Regulations: International Traffic in Arms Regulations (ITAR) U.S. Munitions List (USML) • • • • • • • • • • Firearms Artillery Projectors Ammunition Launch Vehicles, etc... Explosives, Propellants, Incendiary Agents and Their Constituents Vessels of War and Special Naval Equipment Tanks and Military Vehicles Aircraft and Associated Equipment Military Training Equipment Protective Personnel Equipment • • • • • • • • Military Electronics Fire Control, Range Finder, Optical and Guidance and Control Equipment Auxiliary Military Equipment Toxicological Agents and Equipment and Radiological Equipment Spacecraft Systems and Associated Equipment Nuclear Weapons Design and Related Equipment Classified Articles, Technical Data and Defense Services Not Otherwise Enumerated Submersible Vessels, Oceanographic and Associated Equipment AGENCY: U.S. Department of Commerce, Bureau of Industry and Security (BIS) Regulations: Export Administration Regulations (EAR) Commerce Control List (CCL) 0 - Nuclear Materials, Facilities and Equipment and Misc. 1 - Materials, Chemicals, Microorganisms and Toxins 2 - Materials Processing 3 - Electronics 4 – Computers 5 - Telecommunications and Information Security 6 - Lasers and Sensors 7 - Navigation and Avionics 8 - Marine 9 - Propulsion Systems, Space Vehicles and Related Equipment AGENCY: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) Sanctions programs Specially Designated Nationals List * Cuba, Iran, Sudan, Syria Impact on Universities • Wide variety of activities – – – – – International collaborations International shipments Type of equipment/materials we purchase on campus Travel/work with sanctioned countries Research must be unrestricted Some assertions I’ve heard…. “What I am sending (overseas) is commercial, it has no military value.” “You can purchase it overseas so it can’t possibly need an export license.” “I’ve done this for years.” Faculty Outreach Completed in 2011/12 • 3 of 4 Physical Sciences Departments • 2 presentations to Engineering faculty • Participation of Associate Dean of Engineering on Advisory Committee • Updated statement of support for compliance from VCR on 5/12 Outreach Planned for 2012/2013 • • • • School of Social Sciences – faculty CITI training Shipping overview for administrators Update roles/responsibilities in policy guidance Department Purchases • Watch out for export control terms! International Shipments • Contact me for a review of the item/s • Tools – Decision tree: http://apps.research.uci.edu/ecdt/ – Export Control Review Instructions http://www.research.uci.edu/ora/forms/exportcontrol/ExportControlReview.doc – Or call me • DOCUMENTATION – 5 YEARS • American Cargo Service – freight forwarder http://www.ucop.edu/purchserv/psa_db/pubregisterindex.php?mode=1&id=418 Michael Bixler: 858-565-4125 mbixler@acssan.com – Assistance with freight logistics, customs brokerage, have power of attorney – Air Sea Freight Forwarders no longer has power of attorney Where to go for help? Marci Copeland Export Control Administrator E-mail: m.copeland@uci.edu Matters related to educational activities Cuba Padona Yeung (510) 987-9478 Padona.Yeung@ucop.edu Export Control Website http://www.research.uci.edu/ora/exportcontrol/ CITI Export Control Course http://www.research.uci.edu/ora/exportcontrol/CITIcourse.htm