Report Suspected Export Control Violations or Concerns

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 Call the University Compliance hotline at 314-362-4998 Submit the online reporting form Individuals may report anonymously. The Export Control Manager will investigate the suspected violation by […]

Export Control

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 Export Control Office Staff Hollie Noia Manager, Research Compliance & Integrity 314-747-1378 Jennifer Huang Senior Research Compliance Specialist, Export Control/CRI/ESCRO

Find Penalties for Violations

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 […]

Know Which Countries, Entities, and Persons are Restricted

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 […]

Know Which Types of Items are Controlled

“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 […]

Determine Agency Jurisdictions Over Exports

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 […]

Define “U.S. Person” vs. “Foreign National”

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.

Determine When Export Control Laws Apply

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 […]