The Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) govern not only the shipment or transfer of export-controlled technical data, information, materials, and equipment to destinations outside the United States, but also the provision of access to certain export-controlled technical data, information, materials, or equipment to non-U.S. persons within the United States. In addition, the Office of Foreign Assets Control (OFAC) regulations impose sanctions and embargoes on transactions or exchanges with designated countries, entities and individuals. The export regulations are in place to protect not only the economic vitality of the United States, but also to ensure that our technologies are not diverted and used against us. Violations of the export controls laws can undermine efforts to protect against attack or prevent international criminal activity. The University of Arizona recognizes that these laws support vital national security, economic, and foreign policy interests.
Export Control Liaisons
It is important to identify and manage export control issues as early as possible in the consideration of a research proposal and prior to the commencement of any research or activity with export control implications. For this reason, the University Export Control Program (UECP) has established a network of Export Control Liaisons within the various research departments and other units to address export control issues and coordinate the flow of such relevant information to and from UECP.
Liaison members represent a variety of department functions including, but not limited to, finance, operations, contract administration, faculty, purchasing, payroll, tech transfer, and human resources. Working in collaboration with liaison members, UECP has established procedures, processes, and checklists to be used during the review of proposals, contracts, awards, sub-awards, travel requests, hiring requests, visitor requests, and purchasing requisitions to help determine if export control concerns exist. Examples of such concerns or “red flags” would be the inclusion of publication restrictions in contracts, U.S. person restrictions, campus research locations, projects related to military and space applications, and foreign party project involvement.
The appointment of liaisons enables the University to be proactive rather than reactive in catching and resolving export control issues before they occur. By working together, UECP and the Liaisons can meet university objectives to expedite the export control review process, lower the risk of possible export control violations, and become the standard for “best practices” in university export control programs.
Liaison forms, checklists, and procedures can be found at the Liaison Toolbox.
The Director of the University Export Control Program has been designated as the University's primary Empowered Official for export controls, with the authority to make export controls determinations and government license submissions on behalf of the institution. Questions can be directed to firstname.lastname@example.org.