Why is Export Control Important?
- Protects National Security and US foreign obligations
- Combats Terrorism
- Prevents the spread of weapons of mass destruction (nuclear, chemical, biological, etc.)
Liability and Violations Can Result in:
Individual & institutional penalties:
- Large fines & jail time ($500K Civil & $1M Criminal)
- There can be multiple violations/finding for the same occurrence
Not just you - Violations could have UMCES-wide impact
- All settlements are public
- Draconian compliance and reporting could be implemented
- Loss of institution export privileges (exporting is not a right!)
- Adverse impact on federal awards
University Violations
- U of Tennessee: Dr. J. R. Roth, Fine & Jail time
- UCLA: Supported a conference in Iran – OFAC
- UC Santa Cruz civil enforcement action: 5 yr look-back rule
- Texas Tech Dr. T. Butler, 2 yrs in prison & $37,400 fine
Voluntary disclosure helps mitigate penalties!
RED FLAGS
- Restrictions on publishing research results (other than normal patent reviews)
- Restrictions on researcher participation (faculty, student, or others) based on country of origin or citizenship
- Indications from the sponsor or others that export-controlled information or technology will be furnished for use in the research
- The physical export of controlled goods or technology