Export Control Regulations

What Are the Responsibilities of the Principal Investigator?

Primary compliance responsibility with the export control laws and regulations rests with the Principal Investigator (PI). The University will assist the PI in fulfilling those responsibilities.

Prior to commencing any research project that may be subject to export control laws and regulations, the Principal Investigator should notify the Office of Research Administration (ORA) that work is being planned that may be subject to export controls under EAR, ITAR or OFAC. Those officials and/or their staffs will conduct a review to determine if the work is subject to export controls.

If it is determined that no exclusions apply for the contemplated research, before starting work on the research project, the investigators will cooperate with ORA staff to manage the specific export control issues. Management mechanisms include, but are not limited to the following:

A customized Technology Control Plan (TCP) that will outline the provisions for protecting the controlled technology and technical data such as physical/information security plans and end-of-project security measures;
Export Control Training for all the personnel involved in the project;
Personnel screening against Denied Persons Lists;
Obtaining an export license from the appropriate federal agency, if required.

During the project, it is the responsibility of the PI to inform the Office of Research Administration of any changes to the scope of the project and addition to the project personnel for reevaluation of the export control mechanisms in place. The TCP will be updated accordingly. The PI and the project personnel will ensure that access of foreign nationals to the restricted data or technology is denied unless an export license has been obtained. It is PI’s responsibility to report to OVPR any violations of export control laws and regulations related to his/her export controlled project.

At the completion of the project and/or when leaving/terminating University employment, the PI will ensure that the restricted technology will be securely removed/stored and the restricted technical data will be disposed off according to end-of-project security measures outlined in the TCP.