海角官方首页 Policy Regarding U.S. Export Controls and Sanctions Laws
IV-99.00(A) | Research | Approved January 20, 2017
Responsible VP/AVP: Susan C. Buskirk, DM, MS
Revision History
Elevate and update existing Office of Research and Development policy to central library.
Policy Statement
I. INTRODUCTION
U.S. law and regulations restrict the export, transfer, and disclosure of certain technical and scientific data, software, and tangible items. Sanctions and embargoes maintained by the U.S. restrict or prohibit activities, financial transactions, and other transactions with sanctioned individuals, organizations and countries. The reach of the regulations is broad. Certain transactions that might not be regarded as "exports" in other contexts may constitute an export subject to regulations and embargoes.
The University of Maryland, Baltimore ("海角官方首页") is committed to compliance with applicable laws and regulations governing U.S. sanctions, embargoes, traffic in arms, and the export of goods, assets, technology and information. This policy is designed to promote compliance in transactions and collaborations with foreign persons (whether or not in the U.S.) and foreign organizations.
II. APPLICABILITY
This Policy applies to all activities using 海角官方首页 resources and/or conducted by 海角官方首页 Personnel that may result in an export or other transaction with a foreign national, entity, or country which is subject to Export Controls and which requires an export license or other government approval.
This policy is designed to complement, but not supersede, other applicable federal, 海角官方首页, and other policies, including without limitation the University System of Maryland Policy on Classified and Proprietary Work (IV-2.20).
III. DEFINITIONS
"Export Controls and Sanctions" means all applicable laws and regulations governing U.S. sanctions, embargoes, traffic in arms, and the export of goods, assets, technology and information. Export Controls and Sanctions include without limitation regulations under U.S. Department of Treasury, Office of Foreign Assets Control (OFAC, 31 CFR §§500-599); U.S. Department of Commerce Export Administration Regulations (EAR, 15 C.F.R. 730鈥�774); and U.S. Department of State International Traffic in Arms Regulations (ITAR, 22 CFR 120鈥�130).
"Export Officer" means a person who is responsible to oversee 海角官方首页 compliance with Export Controls and Sanctions, and who is legally empowered in writing by the University to sign export license applications or other requests for approval on behalf of 海角官方首页.
"海角官方首页 Personnel" means all 海角官方首页 employees, full鈥恡ime and part鈥恡ime, including student employees; students; consultants; visitors; and others using 海角官方首页 resources.
IV. POLICY
海角官方首页 and its personnel must comply with applicable laws and regulations governing Export Controls and Sanctions. 海角官方首页 Personnel must comply with the provisions of any license, conditions of any other government approval, policy or 海角官方首页鈥恉irected certification, technology control plan, or procedure if an export, activity, or transaction is subject to Export Controls and Sanctions.
The 海角官方首页 President or designee will appoint one or more Export Officers to oversee and manage 海角官方首页 compliance with Export Controls and Sanctions. The Export Officer is authorized to sign applications for export licenses and other requests for government approval on behalf of 海角官方首页. The Export Officer has independent authority to: (i) inquire into any aspect of a proposed export; (ii) verify the legality of an export transaction and the accuracy of the information to be submitted; and (iii) approve or disapprove any license application or other request for approval. The Export Officer may act through designees, including personnel of the 海角官方首页 Office of Research and Development.
To implement this Policy, the Export Officer will document and disseminate information on roles and responsibilities and procedures for identification, approval, and tracking of items or activities subject to Export Controls and Sanctions. Record鈥恔eeping, awareness training, and procedures for self鈥恆ssessments will be addressed by the Export Officer.
V. VIOLATIONS AND PENALTIES
Violation of Export Controls and Sanctions by 海角官方首页 Personnel may subject the violator to remedial or disciplinary action by 海角官方首页 for misconduct, including termination or dismissal. In addition, 海角官方首页 and the 海角官方首页 Personnel may be subject to civil and criminal penalties under applicable law.
VI. RELATED POLICIES