Export ControlsMarci Copeland

Office of ResearchExport 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 Instructionshttp://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 CopelandExport Control AdministratorE-mail: m.copeland@uci.edu

Matters related to educational activities CubaPadona Yeung (510) 987-9478Padona.Yeung@ucop.edu

Export Control Websitehttp://www.research.uci.edu/ora/exportcontrol/

CITI Export Control Coursehttp://www.research.uci.edu/ora/exportcontrol/CITIcourse.htm