University of Arizona employees working on an export-controlled project with a Technology Control Plan (TCP) must complete export control training prior to working on a project and/or accessing export-controlled items or data. Agreements will not be processed by Contracting Services until training is confirmed as current and the TCP is in place.
Is export control training available?
Yes! University of Arizona faculty, staff and students can take any of the export control training modules available through the EDGE Learning system or the Collaborative Institutional Training Initiative (CITI) Program. For more information on the modules available contact Export Control or visit our website.
What are the potential penalties for not following export control regulations?
Penalties for export control violations are substantial, including significant fines, debarment from participation in federal contracting, loss of export privileges, and in some cases imprisonment.
In addition to these severe penalties, the potential reputational damage to an institution from violation of these laws could be difficult to repair, possibly resulting in lost opportunities for attracting world-class researchers and/or decreased access to research funding.
What is the DOE foreign person access requirement?
A recent regulatory change was made to DOE Order 142.3A (December 13, 2019). The clause may be in DOE agreements awarded after December 2019 as well older DOE agreements that are being amended by DOE to include this revision. The revised 142.3A requires prior approval of Foreign Nationals working on DOE projects (including U.S. Permanent Residents). Contact Export Control for assistance with navigating this process.
How does the University vet foreign partners before traveling abroad?
Prior to travel, to avoid collaborating with a prohibited party, foreign parties should be screened using the Restricted Party Screening tool. Export Control or your Department Administrator can assist with conducting screenings.
Is a license necessary to travel to or conduct activities (even remotely) with sanctioned countries?
Depending on your destination(s), authorization from the U.S. Treasury’s Office of Foreign Assets Control (OFAC) may be required. Travel to an embargoed/sanctioned country (e.g., Cuba, Iran) may require prior authorization in the form of a license. If travel to an embargoed country is for personal reasons, no University equipment may be taken, and no University business should be conducted without prior authorization. Most activities involving Iran (even remotely) will require a license.
How do OFAC regulations impact the university?
The purpose of the OFAC regulations is to enforce embargoes and economic sanctions. In general, the OFAC regulations prohibit exports to certain sanctioned/embargoed countries such as Iran, Cuba, Sudan, North Korea, and Syria.
What is a sanctioned country?
Sanctioned Countries are designated by the U.S. Government as having limited or comprehensive trade sanctions and embargoes imposed for reasons of anti-terrorism, non-proliferation, narcotics trafficking, or other reasons. Sanctions are prohibitions on transactions (e.g., financial exchanges, providing or receiving services of value) with designated countries, entities, or individuals.