The USU Export Compliance Program assists University Personnel with the identification and management of research projects subject to U.S. export control laws. The program falls under the auspices of the Office of Research and is managed by the University’s Export Control Officer (ECO), who reports to the Vice President for Research. The Director of Research Integrity and Compliance currently serves as the ECO. The Vice President for Research has been designated as the University’s Empowered Official (EO) for export control purposes.
The Export Control Officer
The Export Control Officer (ECO) assists members of the University community to assess their export control obligations and facilitates the procurement of required export licenses. The ECO is responsible for the following:
- Reviewing and approving Technology Control Plans (TCP);
- Making determinations on export classifications and licensing requirements;
- Approving license applications on behalf of USU;
- Discussing and recommending action on issues presented to the program;
- Developing and maintaining USU’s export control policies and procedures;
- Recommending training priorities; and
- Monitoring export-controlled projects for regulatory compliance.
Because violation of U.S. export control regulations can result in fines and sanctions against both individual research and USU, USU policy requires all University Personnel to be aware of and comply with export control regulations and applicable University policies and procedures. With regard to specific research projects, USU policy places primary compliance responsibility on researchers. All researchers are expected to notify appropriate administrative staff when they suspect that export control laws apply to their research and to ask the ECO for assistance in making a determination, when necessary.
Faculty/Researcher/Principal Investigator
- Identify research activities in which export control issues might exist.
- Notify the ECO of identified export control issues.
- Work with the ECO to put technology control plans (TSPs) in place and accurately classify items for licenses.
- Inform research team members of any applicable export control requirements, including TCPs pertaining to the project.
- Ensure the appropriate protection and management of all export-controlled technology in his/her possession.
- Provide all export documentation to the ECO for archiving.
Research Administrators
The Research Administrator, or any person preparing research proposals or sponsored research grants or agreements will:
- Answer the export control question(s) and provide relevant information to enable a review by the ECO.
- Identify language in proposal or requests for proposals that attempts to place restrictions on the university’s ability to publish the research or to place restrictions on the participation or access by Foreign Nationals.
- Notify the ECO in the event that such restrictions are identified.
Department/College/Unit Director/Dean
- Approve the TCP’s of their faculty members.
- Administer and monitor existing TCPs of their faculty members.
- Notify the ECO of any issues that arise regarding the implementation of, or compliance with, any TCP.
Empowered Official
The Empower Official (USU’s Vice President for Research) will:
- Decide when a proposed activity cannot be conducted at USU.
- Sign license agreements on behalf of USU.
- Accepts liability in communication with ITAR violations.