Any individual who suspects that an export control violation has occurred should notify the university through one of several channels: Contact the Export Control Manager directly at OVCRExportCompliance@wustl.edu Call the University Compliance hotline at 314-362-4998 Submit the online reporting form http://universitycompliance.wustl.edu/code-of-conduct/online-reporting-form/. Individuals may report anonymously. The Export Control Manager will investigate the suspected violation by […]
Export control oversight, including the development and implementation of procedures to promote the University’s ongoing compliance with export control laws and the development of training and education for faculty and staff
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Civil Penalties EAR ITAR OFAC University Up to $120,000 per violation Up to $500,000 per violation Up to $55,000 per violation Individual (PI) Up to $120,000 per violation Up to $500,000 per violation Up to $55,000 per violaton Criminal Penalties EAR ITAR OFAC University Up to $1 million per violation Up to $1 million […]
Restricted Countries, Entities, and Persons The U.S. Department of the Treasury, through its Office of Foreign Assets Control (OFAC), enforces U.S. embargo and sanction programs that may restrict transactions with certain foreign countries irrespective of whether the exported technology is controlled under the ITAR or the EAR. Sanctions programs vary in severity. In cases where a country is […]
“Dual-Use” Technologies The controlled technologies most commonly found on campus are “dual-use” technologies covered by the Export Administration Regulations (EAR). These are items or technologies with potential for both civilian and military use (the military use may not be obvious). Dual-use items can be found on the Commerce Control List (CCL). Each category on the CCL […]
Two primary sets of regulations govern the export of controlled technologies: the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). The ITAR, which are administered and enforced by Department of State through its Directorate of Defense Trade Controls (DDTC), regulate the export of military, space, and satellite technologies. The EAR, which are administered and enforced […]
A “U.S. Person” is defined as a: Lawful Permanent Resident U.S. Citizen Legal Immigrant with a “Green Card” Protected Individual granted asylum or refugee status “Foreign National” includes everyone else, including foreign governments or entities not incorporated to do business in the U.S.
What is export control? Export control laws regulate the export of commodities, related technical data and information, and certain services the federal government considers critical to the national security or domestic economy of the United States. The export control laws also regulate the transfer of controlled technical data to foreign nationals within the United States (“deemed exports”). “Exports” are […]