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Export Control Management

Export Control Management. Plan Development and Implementation. July 24, 2007. Areas of Exposure for Universities. Unlawful or improperly documented exports Deemed Exports Payments to denied persons or entities. Areas of Impact on Campus. Personnel – faculty/staff recruitment

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Export Control Management

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  1. Export Control Management Plan Development and Implementation July 24, 2007

  2. Areas of Exposure for Universities • Unlawful or improperly documented exports • Deemed Exports • Payments to denied persons or entities

  3. Areas of Impact on Campus • Personnel – faculty/staff recruitment • Admissions – graduate and undergraduate • Research and technology transfer • Accounting, procurement, materials management, capital asset control • Faculty International Travel • Campus Visitors

  4. Key Aspects of Campus Management Plans • Establish node of expertise and name an empowered official – demonstrable management commitment to compliance • Establish and distribute policies and procedures and adopt good documentation practices • Provide training for administrators, faculty and staff • Monitor for compliance and self-report non-compliance

  5. Assess the Campus Environment“Know the Rules” • Federal Regulations • Be familiar with key concepts • Understand the subtle differences between the various regulations • Understand the emerging profile of export controls regulations and consequences for non-compliance • Get buy-in endorsement from the top

  6. Assess the Campus Environment“Know What You Have” • Conduct an environmental scan • Identify laboratories or specialized equipment that could be subject • Identify students and faculty from restricted countries by program /department • Identify key faculty, department heads and center directors

  7. Assess the Campus Environment“Know Where People Go” • International Travel • Review and Approval • Understand restrictions for what can be taken • International Visitors • Point of Invitation • Access to facilities

  8. Assess the Campus Environment“Know Who You Do Business With” • Financial transactions • Procurement/Accounts payable • Honorarium payments • Materials Management • Shipment to restricted countries • Shipment of subject materials • Documentation

  9. Start with Good Documentation • Policies and Procedures • Grounded in the federal regulations • Involve key stakeholders in development • Clearly articulate roles and responsibilities • Linked to corresponding policies in other administrative units • Incorporate a communication plan • Broadly distributed

  10. Process and Monitoring • Conduct Base-Line and Periodic Inventory • Restricted Persons (current and new) • Dual Use or Controlled Technologies • Documentation • Departing PIs and Post-Docs • International travel and visitors • Develop checklists

  11. Training is Key • Revamp compliance training • New Faculty • New Graduate Students • Handbooks and administrative policies and procedures

  12. UNC Technical Assistance • Campus briefings • Group briefings • Support for web-based information resources

  13. Next Steps • Secure management statement • Engage various sectors in development of procedures • Train faculty and staff • eCustoms training for academic, research and business units

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