Export Control Training Requirement

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Export Control Training Requirement

Subject: Export Control Training Requirement

TO:          Campus Community
FROM:    Leslie P. Tolbert, Senior Vice President for Research
DATE:      October 15, 2012
Research in a university setting generally is conducted openly and without restrictions; however, there are certain conditions under which a University research project and related activities may be subject to United States export control laws and regulations, including those implemented by the Department of Commerce (DoC) through its Export Administration Regulations (EAR) and by the Department of State (DoS) through its International Traffic in Arms Regulations (ITAR), and sanctions and embargo regulations imposed by the U.S. Treasury Department through its Office of Foreign Assets Control (OFAC).

These laws and regulations apply restrictions on the transmission of information or technology that are very different from the usual pattern of open university research. The consequences of violating these regulations can be quite severe, ranging from loss of research contracts to monetary and criminal penalties for the individual and/or university violating the regulations.

To educate University researchers about the export control requirements and to help ensure compliance with these regulations, UA has instituted required export control training for UA employees who are associated with export controlled projects secured by a Technology Control Plan (TCP).

All UA employees working on an export controlled project secured with a TCP are required to successfully complete the online export control training module prior to the start of the project and to take export control continuing education training each year throughout the duration of the secured project. 

The initial and continuing education training on export control requirements can be completed by one of the following options:
•          Complete the online export control continuing education course
•          Attend a UA-sponsored export control presentation on campus.

See http://orcr.arizona.edu/ec/training.

Failure to successfully complete the required initial and annual continuing education training will result in removal from the project until the training has been completed.

Principal Investigators conducting research secured with a TCP are responsible for ensuring that all project personnel complete the required export control training as described above.

All personnel who work on existing projects with a TCP are required to take the online training by November 15, 2012.   Failure to successfully complete the training by this date will result in removal from the project until the training has been completed.

Any time that the UA Export Control Officer (ECO) determines that a project is export controlled and requires a TCP, the Office of Research and Contract Analysis (ORCA) will not process the pertinent sponsored research agreement, contract, or non-disclosure/proprietary information agreement until receiving confirmation that all project personnel have successfully completed the online export control training.  In addition, no work on the project can begin until all project personnel have successfully completed the export control training and the TCP is in place.

The University’s Export Control Officer is responsible for export control training content and for maintaining the training records.

More information about the online training module can be found at http://orcr.arizona.edu/ec/training. Additional export control resources are available at http://orcr.vpr.arizona.edu/export-control and by contacting the Export Control Officer at 520-626-2437.

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