Lend Me Your EARS (AND ITAR, AND OFAC): OVERVIEW

AND EXCHANGE OF BASIC EXPORT CONTROL

STRATEGIES FOR PUIs

Roberta Truscello, truscello@hws.eduDirector of Sponsored Programs

Hobart and William Smith CollegesCarolyn Elliott-Farino, cellio12@kennesaw.edu

Director of Contracting and Grants Administration Kennesaw State University

What We Will Cover TodayToday’s presentation will focus on the actual risk we face (it is low for most of us) and the areas that are most likely to trip us up, and strategies we can use to ensure we capture any potentially problematic situations. We will: • briefly review the EAR, ITAR and OFAC regs• highlight some key concepts and definitions• provide links to some resources where you will find detailed

explanations• discuss situations where you might face an export control issue• share some examples of export controls in action at PUIs

The Problem• You work at an institution that doesn’t have an

export controls officer, and it may not have a compliance officer, either. How do you make sure your institution is following federal regulations vis-à-vis export controls for sponsored projects?

• You know something about the export regulations, and know that you need to be aware of them, but you aren’t really sure if you have any export-controlled situations at your institution.

• There are sessions on export controls at national and regional meetings, and the Commerce Department and State Department conduct training seminars. These sessions do a great job explaining the regulations and what to do if your project is export-controlled. They give detailed instructions on obtaining a license.

• This information is very helpful, but for those of us with little exposure to controlled research or technology, it can be information overload and it doesn't answer a central question: Do we need to worry about this? How do we determine that this is something we need to worry about? What are the situations that are most likely to trip up my institution?

• We assume we have a low risk of exposure – is this dangerous?

What We Will Cover TodayToday’s presentation will focus on the actual risk we face (it is low for most of us) and the areas that are most likely to trip us up, and strategies we can use to ensure we capture any potentially problematic situations. We will: • briefly review the EAR, ITAR and OFAC regs• highlight some key concepts and definitions• provide links to some resources where you will find detailed

explanations• discuss situations where you might face an export control issue• share some examples of export controls in action at PUIs

What We Will Not Cover TodayWe will not:• Discuss the licensing process or technology control

plans. If you do have an export controlled situation and need a license, or if you need to implement a technology control plan, there are resources out there – including NCURA sessions – to help you with that. If you think a license is needed, you should contact your institution’s attorney.

Overview of Export Controls: What Are They?• EAR (Export Administration Regulations) – Department of

Commerce, Bureau of Industry and Commerce (BIS) – commercial or military use (“dual use”), but primarily commercial

• ITAR (International Traffic in Arms Regulations) – Department of State, Directorate of Defense Trade Controls (DTTC) – military use

• OFAC (Office of Foreign Assets Control) Sanctions – Department of Treasury – economic and trade sanctions against targeted foreign governments, individuals, entities, practices

Good sources for reviewing the regulations in detail include: • http

://doresearch.stanford.edu/research-scholarship/export-controls

• www.bc.edu/content/dam/files/research/ppt/BCExportControls1.ppt

• http://www.cogr.edu/Pubs_ExportControls.cfm• The websites of many research universities. Most of

the big ones have export control officers and well developed websites with good resources for universities.

Definition: What Is An Export?• Physical shipment of a controlled item or goods• Transmission (electronic or digital) of a controlled item or

information related to a controlled item• Release or disclosure (including verbal or visual) of controlled

technology, software or technical data, either in the US or abroad• Use or application of controlled technology on behalf of, or for the

benefit of, any foreign person or entity, either in the US or abroad• The controlled item itself, including information or software, is also

referred to as an “export”• “Deemed exports” are treated as exports, and include release of

controlled information to a foreign national in the US

Definition: What is a Deemed Export?A deemed export occurs when export controlled information, technology or material is disclosed or released to a foreign person in the US. In these cases, an export is considered (“deemed”) to have been made to the recipient’s home country or last country of citizenship.

Key Concept: “Persons” with Regard to Exports • US Person – a US citizen, permanent resident (Green Card

holder), refugee, or person under amnesty or political asylum. Also includes organizations and entities (such as universities) incorporated in the US.

• Foreign person – anyone who is not a “US Person,” including students, post-docs, or research staff in the US on a visa. Also includes foreign corporations, business associations, partnerships, or any entity or group not incorporated in the US. May include international organizations, foreign governments and their agencies or subdivisions.

A Brief Overview of: 1. EAR 2. ITARand later,3. OFAC

1. EAR ( Export Administration Regulations)• Who? Bureau of Industry and Security (BIS) of the

Department of Commerce.• The EAR implement the Export Administration Act

and apply to most commercial items, including dual-use items.

• Dual-use items: items that have both commercial and military or proliferation applications. Term is used informally to describe items subject to the EAR.

• 15 CFR 730-774http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=15:2.1.3.4.20&idno=15

• http://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear

• http://www.bis.doc.gov/index.php/forms-documents/doc_view/412-part-734-scope-of-the-export-administration-regulations

• BIS regulates:– Exports, including “deemed” exports– Reexports– Certain transfers of items “subject to the EAR” – Certain activities of US persons

• What is an item?– Commodities– Software– Technology (knowledge how to design, produce, or use

something)

Subject to the EAR • All items in the US, EXCEPT:– publicly available technology and software (excluding

encryption); – items subject to the exclusive jurisdiction of another

federal department or agency;– literary publications, such as newspapers or literary

works (non-technical in nature)• US origin items wherever located• Certain foreign-made items

• Commerce Control List (CCL), Supplement No. 1 to Part 774 of the EAR: contains the list of items subject to the licensing authority of the BIS. http://www.bis.doc.gov/index.php/regulations/commerce-control-list-ccl

• EAR 99: Items subject to the EAR which are not listed on the CCL are designated as “EAR99.” – low-technology consumer goods, usually do not require a

license– if you plan to export an EAR99 item to an embargoed

country, to an end-user of concern, or in support of a prohibited end-use, you may be required to obtain a license

• Who is subject to the EAR?– Certain activities of US persons related to the

proliferation of nuclear explosive devices, chemical or biological weapons, or missile technology.

– Activities of US or foreign persons prohibited by any order issued under the EAR.

2. International Trafficking in Arms Regulations (ITAR)

• Who? Directorate of Defense Trade Controls (DDTC) of the Department of State.

• ITAR implement the Arms Export Control Act (AECA) and governs defense articles and defense services.

• 22 CFR 120-130http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=b42b901932e65d5d410781b6bcccd6a1&rgn=div5&view=text&node=22:1.0.1.13.57&idno=22

• http://pmddtc.state.gov/regulations_laws/itar_official.html

• Defense articles: – Any item or technical data designated on the US

Munitions List (USML) http://pmddtc.state.gov/regulations_laws/documents/official_itar/ITAR_Part_121.pdf

– Includes technical data recorded or stored in any physical form, models, mock-ups or other items that reveal technical data

– Technical data: Blueprints, drawings, photographs, plans, instructions, documentation, or software application programs for the design, development, testing, production, repair, etc. of defense articles

• Defense Services:– Furnishing of assistance, including training, to

foreign persons in the US or abroad – encompasses the design, development, engineering, manufacture, production, assembly, testing, repair, maintenance, modification, operation, demilitarization, destruction, processing or use of defense articles

– Military training of foreign units and forces

Fundamental Research and the Fundamental Research Exclusion

Fundamental ResearchNational Security Decision Directive (NSDD) 189 defines fundamental research:

"'Fundamental research' means basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community, as distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons."

The Fundamental Research Exclusion (FRE)No license is needed to disclose technical information to foreign nationals inside the US if the information is in the public domain. This includes information published and generally accessible to the public through “fundamental research in science and engineering at accredited institutions of higher learning in the US where the resulting information is ordinarily published and shared broadly in the scientific community.” (EAR 734.8; ITAR 120.11(8))

• The Public Domain means information that is published and generally accessible to the public, e.g.:– Sales at newstands– Subscriptions– Mailings– Libraries– Unlimited distribution at a conference– Fundamental research

Why is the FRE Important for Universities and Colleges?

• The FRE is important to academic institutions because it will probably apply in at least 90% of your potential export situations. If the FRE applies, you do not need to apply for a license. • The FRE does not apply to the export of

tangible goods, biological materials, source code, or software.

What Can Destroy the FRE?• Acceptance of restrictions on the publication of

scientific and technical information resulting from the project or activity. For the FRE to apply, the results must “ordinarily be published and shared broadly.”

• Acceptance of restrictions on the use of foreign nationals in the research.

• Acceptance of specific national security controls on a research project or activity sponsored by the U.S. Government.

What If the FRE Doesn’t Apply?• Is this an export, including a deemed export?• If the answer is “no”, you don’t have to worry

about export controls at this time. This may change in the future if the participation of foreign national is envisioned.

• If the answer is “yes”…

Let’s look at the definitions of export and deemed export again…

Definition: What Is An Export?

• Physical shipment of a controlled item or goods• Transmission (electronic or digital) of a controlled item or information

related to a controlled item• Release or disclosure (including verbal or visual) of controlled

technology, software or technical data, either in the US or abroad• Use or application of controlled technology on behalf of, or for the

benefit of, any foreign person or entity, either in the US or abroad• The controlled item, information or software is also referred to as an

“export”• “Deemed exports” are treated in the same way as exports (involve

release of controlled information to a foreign national in the US)

Definition: What is a Deemed Export?A deemed export occurs when export controlled information, technology or material is disclosed or released to a foreign person in the US. An export is considered (“deemed”) to have been made to the recipient’s home country or last country of citizenship.

Highlight: Deemed Exports & PUIsDeemed export situations are not always obvious and can therefore be problematic for PUIs. Even if no PI travel is involved, no one is paid, and nothing is being physically shipped or emailed, you may still have an issue if a project involves or allows:• Foreign students (paid or unpaid)• Foreign national staff (paid or unpaid)• Symposium attendees or program participants from other

countries• Visiting scholars, or people touring labs

Exports & Deemed Exports: Possible Red Flags• Foreign persons, including students, post-docs, and

staff working in labs or on sponsored projects. They do not have to be paid in order for there to be an export issue.

• Collaborations with non-US corporations and multi-national corporations. If controlled and FRE does not apply, you may need a license. A US corporation with an abroad division may also be a foreign person, as are foreign governments and their subdivisions.

Exports & Deemed Exports: Possible Red Flags• Faculty or student projects involving foreign

companies or US companies with offices or divisions abroad – if controlled and no FRE, you may need a license.

• International travel, especially with a laptop. We will cover this under sanctions.

If the FRE does not apply and this is an export, including a deemed export, you need to ask:–What is the item? Is it controlled?–Where is it going?–Who will receive it?–What will be the end-use?

• At this point, you need to work with the PI to classify the export item:–CCL–USML –Vendor software such as Visual

Compliance

• If the research is not subject to the FRE and controlled technology is involved:– The research may need to be restructured.–A technology plan will be required.– You may need a license. Consult the BIS or

DTTC webpages for licensing information.

3. Sanctions, including OFAC Sanctions

http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx

Red Flag: State Sponsors of Terrorism: Cuba, Iran, Sudan, Syria*

Countries determined by the Secretary of State to have repeatedly provided support for acts of international terrorism are designated pursuant to three laws: section 6(j) of the Export Administration Act, section 40 of the Arms Export Control Act, and section 620A of the Foreign Assistance Act. Taken together, the four main categories of sanctions resulting from designation under these authorities include restrictions on U.S. foreign assistance; a ban on defense exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions.* current as of 7/27/13

Office of Foreign Assets Control (OFAC)• OFAC administers a number of different

sanctions programs. The sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals.

• Specially Designated Nationals List (SDNL)

Red Flag: Working with Comprehensively Embargoed and Targeted Countries

• Be vigilant – you are likely to need a license and/or may not be able to export

• Seek advice from university counsel or other institutional officials before proceeding further

Red Flag: OFAC & EAR Comprehensively Embargoed Countries (Cuba, Iran, Syria)

• Under OFAC and EAR, Iran, Cuba, and Syria are subject to comprehensive embargoes that prohibit virtually all exports/imports and other transactions without a license or other US Government authorization.

http://doresearch.stanford.edu/research-scholarship/export-controls/export-controlled-or-embargoed-countries-entities-and-persons

• Cuba:– All items on the CCL require a license. – EAR99 items require license.– General policy of denial.– Some license exceptions.

• Iran:– License requirements and other restrictions on exports and reexports

to Iran.– Comprehensive embargo on transactions involving Iran administered

by OFAC.• Syria:

– Prohibition on export to Syria of products of the US, other than food and medicine.

Red Flag: Targeted Sanctions Countries

OFAC• Libya, Lebanon, Somalia, Belarus, Sudan,

North Korea, Iraq, Yemen, Myanmar (formerly Burma), Liberia, Zimbabwe, Balkans, the Cote D'Ivoire (formerly Ivory Coast)

EAR• North Korea, Iraq

Countries with Restricted Entities on the EAR Entity Chart• China, Canada, Germany, Iran, India, Israel, Pakistan,

Russia, Egypt, Malaysia, Hong Kong, Kuwait, Lebanon, Singapore, South Korea, Syria, United Arab Emirates the United Kingdom.

ITAR Prohibited Countries• Afghanistan, Belarus, Cuba, Cyprus, Eritrea, Fiji, Iran, Iraq,

Cote d'Ivoire, Lebanon, Libya, North Korea, Syria, Vietnam, Myanmar, China, Haiti, Liberia, Rwanda, Somalia, Sri Lanka, Republic of the Sudan (Northern Sudan), Yemen, Zimbabwe, Venezuela, Democratic Republic of the Congo.

Red Flag: Travel With Laptops and other Mobile Devices

• Not strictly a sponsored program issue, but one of the most likely areas where a PUI can run afoul of export control laws.

• There are two license exceptions for travel with items and software containing encryption code (laptops, mobile devices):

• License Exception TMP (Temporary Exports) allows those departing from the US on university business to take with them as "tools of the trade" institution-owned or controlled, retail-level encryption items such as laptops, smartphones, and encryption software in source or object code to all countries except Sudan and Cuba, as long as the items and software will remain under their "effective control" overseas and are returned to the US within 12 months or are consumed or destroyed abroad;

• License Exception BAG (Baggage) allows individuals departing the US either temporarily (travel) or longer-term (relocation) to take with them as personal baggage family-owned retail-level encryption items including laptops, smartphones, and encryption software in source or object code. The encryption items and software must be for their personal use in private or professional activities. Citizens and permanent resident aliens of all countries except Cuba, Libya, Syria, Sudan, North Korea and Iran may take with them as personal baggage non-retail "strong" encryption items and software to all locations except embargoed or otherwise restricted locations.

You cannot export without a license: • ITAR-controlled articles, technical data, such

as a document or drawing, or software on your laptop without a license from the State Department.

• Tangible items developed through fundamental research which was excluded from export controls are still subject to the ITAR. Only the research results are excluded.

• US persons can use the exceptions to take EAR-controlled technology, but this does not authorize its transfer to someone not otherwise authorized to receive it.

• Non-US persons cannot take EAR-controlled technology out of the US, even if it has been transferred to them as an acceptable deemed export.

OFAC CUBA Travel Sanctions• General License: Faculty, staff and students of U.S. IHEs are

authorized to engage in Cuba travel-related transactions for participation in a structured educational program in Cuba as part of a course offered for credit by a sponsoring U.S. academic institution ; noncommercial academic research in Cuba specifically related to Cuba for the purpose of obtaining a graduate degree; participation in a formal course of study at a Cuban academic institution; teaching at a Cuban academic institution (at least 10 weeks); sponsorship, including the payment of a stipend or salary, of a Cuban scholar to teach or engage in other scholarly activity at a sponsoring U.S. academic institution.

• Specific License: On a case-by-case basis OFAC considers applications for specific licenses to authorize Cuba travel-related transactions not covered by a general license.

• OFAC licensed Travel Service Provider: Use a travel agent specifically licensed by OFAC as a Travel Service Provider.

Red Flag: Working With Foreign Nationals• Check the consolidated screening list located at http://

export.gov/ecr/eg_main_023148.asp• If a company, entity or person on the list appears to match

a party potentially involved in your export transaction, additional due diligence should be conducted before proceeding. There may be a strict export prohibition, requirement for seeking a license application, evaluation of the end-use or user to ensure it does not result in an activity prohibited by any U.S. export regulations, or other restriction.

Department of Commerce – Bureau of Industry and Security• Denied Persons List - Individuals and entities that have been denied export

privileges. Any dealings with a party on this list that would violate the terms of its denial order are prohibited.

• Unverified List - End-users who BIS has been unable to verify in prior transactions. The presence of a party on this list in a transaction is a “Red Flag” that should be resolved before proceeding with the transaction.

• Entity List - Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The list specifies the license requirements and policy that apply to each listed party.

Department of the Treasury – Office of Foreign Assets Control• Specially Designated Nationals List – Parties who may be prohibited from export

transactions based on OFAC’s regulations. The EAR require a license for exports or reexports to any party in any entry on this list that contains any of the suffixes "SDGT", "SDT", "FTO", "IRAQ2" or "NPWMD".”

Department of State – Bureau of International Security and Non-proliferation• Nonproliferation Sanctions - Parties that have been sanctioned under

various statutes. The linked webpage is updated as appropriate, but the Federal Register is the only official and complete listing of nonproliferation sanctions determinations.

Department of State – Directorate of Defense Trade Controls• AECA Debarred List – Entities and individuals prohibited from participating

directly or indirectly in the export of defense articles, including technical data and defense services. Pursuant to the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR), the AECA Debarred List includes persons convicted in court of violating or conspiring to violate the AECA and subject to “statutory debarment” or persons established to have violated the AECA in an administrative proceeding and subject to “administrative debarment.”

Examples

Real PUI Example #1• Your faculty member is a possible candidate for DOD funding to support

a research partnership with a local private company in the area of blood research. The company develops and manufactures blood products.

• The scope of the project includes research into developing a unique method of producing large quantities of plasma.

• One of the company’s researchers would be working in an on-campus lab, and there are a number of exchange students from China who could be working on the project.

• The administration sees this as a great opportunity for students to gain some solid research experience, would be very pleased to receive DOD funding, and is in favor of the collaboration.

What do you do?

Note Possible Red Flags

• Your faculty member is a possible candidate for DOD funding to support a research partnership with a local private company in the area of blood research. The company develops and manufactures blood products.

• The scope of the project includes research into developing a unique method for producing large quantities of plasma.

• One of the company’s researchers would be working in an on-campus lab, and there are a number of exchange students from China who could be working on the project.

• The administration sees this as a great opportunity for students to gain some solid research experience, and is in favor of the collaboration.

Things to ponder:• Does this look like fundamental research that will be covered by the

FRE? • Collaborator is a private US corporation engaged in R&D, and sales…• Funding is from DOD – why would they sponsor this project? • Could there be a possibility for dual-use? • What is the DOD funding instrument going to look like? Possible

restrictions?• Would there be any issues raised by having a Company researcher

working in a campus lab?• Does the presence of foreign undergraduate students in the lab present

a problem?• Do you need outside advice?

Look again at the possible Red Flags

• Your faculty member is a possible candidate for DOD funding to support a research partnership with a local private company in the area of blood research. The company develops and manufactures blood products.

• The scope of the project includes research into developing a unique method for producing large quantities of plasma.

• One of the company’s researchers would be working in an on-campus lab, and there are a number of exchange students from China who could be working on the project.

• The administration sees this as a great opportunity for students to gain some solid research experience, and is in favor of the collaboration.

Conclusion:This collaboration, the aim of which was to develop a plasma product with possible military applications did not go forward. Following a conversation with representatives from the DOC and the FBI, the security issues and screening requirements for personnel appeared too onerous, and the agreement would have included too many special monitoring and compliance requirements.

Real PUI Example #2• A Computer Science faculty member designs and works

with robots. • He collaborates with German colleagues abroad who are

supported by the DLR (Deutsches Zentrum für Luft- und Raumfahrt), which is the German equivalent of NASA.

• He occasionally travels to Germany, but research is taking place in both locations.

• The scope of the work is considered Fundamental Research, under the US definition.

What do you think? Any red flags?

Conclusion:This research is ongoing, and no license was pursued.

Real PUI Example #3• A Physics professor travels regularly to

Denmark to work with colleagues in their labs.• On her next trip, she will be carrying low-

grade carbon nanotubes, valued at under $2000 a piece.

What do you think? Would you have any questions for this PI?

The PI says that the nanotubes are not very high-tech, and they are relatively easy to obtain.

Is that relevant?

Conclusion:This research is ongoing and the school determined that they did not require a license.

Real PUI Example #4• You receive a fee-for-service agreement from a national

research foundation in a Middle Eastern country.• They would like to engage your PI, who is former US

military and an expert in Improvised Explosive Devices (IEDs) and Explosive Ordinance Disposal (EOD)

• The PI would be conducting field training for the organization on dismantling and disposal of IEDs – a peaceful endeavor

Are there red flags?

Conclusion:The location and the possible military applications of the training to be performed raised too many questions. The PUI took a pass on the project, and did not pursue a license.

Real PUI Example #5

• Your faculty member is a Professor of Religion, and comes from a country on the EAR and OFAC Comprehensively Embargoed Countries list

• He does not have a green card, but has a visa that allows him to teach• He regularly travels home to do research and visit family• His expenses include publication and travel, which are always paid in

cash, according to custom.Any red flags? Do you have questions for your PI?

• Also, he wants to give his family some money, the source of which is his salary.

Is that a problem?

Conclusion:After looking very closely at this situation, screening carefully, and talking with the PI on several occasions, the PUI found a way to let this go forward without a license.

What would your questions have been?

Export Control Decision Trees• http://

doresearch.stanford.edu/research-scholarship/export-controls/export-controls-decision-tree

• http://researchintegrity.gatech.edu/about-export/export-decision-tree/

• http://intraweb.stockton.edu/eyos/grantsoffice/content/docs/Compliance%20with%20Export%20Control%20Regulations%20and%20checklist.pdf

• http://www.oria.cornell.edu/export/trees/

Points to Remember

• Export control regulations govern what items can be exported out of the US. Non-compliance can result in fines and/or jail time for those who contravene the law.

What can a PUI do to ensure adherence?• Education/training component for faculty.• Screen any foreign nationals or entities using a screening

tool.• Be vigilant about where people travel and what items

they bring with them (i.e. export). The federal government has embargoes and sanctions on a number of countries.

• Use an NDA to protect vendor/sponsor proprietary information and keep the FRE – the restriction is not on university-generated information.

• Include screening questions on the routing form. Does the project involve: – Military/defense related research, technical services, or training?– Access to/use of proprietary information?– Shipping equipment or computers to a foreign country?– Technologies or devices which might have a military, security, or intelligence

application?– Collaborating with a foreign colleague, even if all activity is in the US?– Training foreign nationals to use software or use?– The use of foreign nationals as research assistants?– Sending research results or information to a foreign country or foreign citizens?– Travel to a foreign country?– Publication restrictions, including approval rights?

• Do nothing to lose the FRE – the FRE allows you to disclose technical data to foreign nationals in the US without a license.– Don’t accept any publication restrictions.– Don’t accept any restrictions on the use of foreign

nationals.– Don’t accept national security controls

• If you do lose the FRE and have an export, work with the PI to classify the item to see if it is controlled.

Sources• http://doresearch.stanford.edu/research-schola

rship/export-controls/overview• http://osp.mit.edu/compliance/export-controls• http://www.oria.cornell.edu/export/• bc.edu/content/dam/files/research/ppt

/BCExportControls1.ppt• http://www.cogr.edu/Pubs_ExportControls.cfm

section VII “Best Practices”

• http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=15:2.1.3.4.20&idno=15

• http://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear

• http://www.bis.doc.gov/index.php/forms-documents/doc_view/412-part-734-scope-of-the-export-administration-regulations

• http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=b42b901932e65d5d410781b6bcccd6a1&rgn=div5&view=text&node=22:1.0.1.13.57&idno=22

• http://pmddtc.state.gov/regulations_laws/itar_official.html

• http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspxwww

• Chapter 3400, Sponsored Research Administration, A Guide to Effective Strategies and Recommended Practices, NCURA

• Complying with US Export Controls, BIS Seminar, Atlanta, GA, March 31-April 1, 2009

• Complying with ITAR Controls, DDTC Seminar, Atlanta, GA, April 2, 2009

• Export Compliance Issues & Examples, Jilda Garton, Region III presentation, May 9, 2006