|Title:||Export Control and Economic Sanctions Policy|
|Policy Owner:||Office of the Vice President for Research|
|Applies to:||Faculty, Staff, Students, Others|
|For More Information, Contact||Research Compliance Services|
|Contact Information:||firstname.lastname@example.org, or (860) 486-8704|
REASON FOR POLICY
Export control and economic sanctions regulations aim to protect the national security, foreign policy, and economic interests of the United States. Export control regulations govern how certain information, technologies, and commodities can be transmitted overseas or to a foreign national on U.S. soil, whereas economic sanctions regulations restrict transactions with certain countries, institutions, and individuals. The scope of the these regulations is broad: they cover exports in virtually all fields of science, engineering, and technology, apply to research activities regardless of the source of funding, and impose restrictions on activities by U.S. persons that occur outside the United States. Failure to comply with these laws can have serious consequences, both for the institution and for the individual researcher. The potential penalties include fines and imprisonment. These laws are collectively referred to as “Export Control Laws.”
The University of Connecticut (UConn) encourages and supports open research and the free exchange of ideas. Although most university activities and research are exempt from export control laws, UConn engages in activities, research, and the development of new technologies that are subject to Export Control Laws. UConn has established the procedures necessary to ensure the university and its employees remain in full compliance.
This policy applies to all faculty, staff, students, researchers, and all other individuals working at the University of Connecticut Storrs, Regional Campuses, and UConn Health.
UConn is committed to compliance with Export Control Laws, including those implemented by the U.S. Department of Commerce through its Export Administration Regulations (EAR), the U.S. Department of State through its International Traffic in Arms Regulations (ITAR), as well as embargo regulations imposed by the U.S. Treasury Department through its Office of Foreign Assets Control (OFAC).
The Office of the Vice President for Research (OVPR) is the designated authority charged with compliance oversight of the U.S. export control and economic sanctions requirements for UConn and has final authority on such matters. Research Compliance Services, an office within OVPR, is the functional administrative unit charged with the responsibility for oversight of export control and economic sanctions compliance and recordkeeping.
Individuals acting on behalf of the University, including faculty, staff and students, are responsible for complying with applicable Export Control Laws, including requirements related to international travel, the proper handling, transfer, access, storage, control, and dissemination of export controlled hardware, software, information, technology, and technical data to destinations and persons outside of the U.S., as well as in some cases, to foreign nationals at the university engaging in instruction, conducting research, or providing service activities.
The University typically conducts fundamental research in basic and applied science or engineering, which is widely and openly published and made available to the scientific and academic community. This allows for the Fundamental Research Exclusion, which means the research results are exempt from Export Control Laws. But Export Control Laws could apply if the research is not considered fundamental research, or if the research has restrictions on publication, foreign national participation, or restricted access to/disclosure of research results. Please contact Research Compliance Services if you have any questions on whether or not Export Control Laws apply to your particular activity.
In order to comply with Export Control Laws applicable to international travel, the University will not permit or support travel to any country subject to a comprehensive U.S. Government embargo (as set forth in the UConn International Travel procedure, unless the travel falls within the scope of a license or exception granted by law and is reviewed in advance and approved in writing by the OVPR Senior Export Control Officer under this policy and the export control compliance protocols and procedures available online at: https://ovpr.uconn.edu/services/rics/export-control/.
Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.
The civil and criminal penalties associated with violating Export Control Laws can be severe, ranging from administrative sanctions including loss of research funding, to monetary penalties, and imprisonment. Anyone found to have engaged in conduct contrary to this policy is subject to disciplinary action by the university up to and including dismissal or expulsion and civil or criminal prosecution.
Export control compliance protocols and procedures are available online at: https://ovpr.uconn.edu/services/rics/export-control/.
Policy created: 12/14/2015 (Approved by the Vice President for Research)
1/12/2016 (Approved and Adopted by the UConn Health Policy Committee)
7/3/2018 (Non-Substantive edits per the Office of General Counsel)
9/18/2018 (Non-Substantive edits per the Office of General Counsel)