I. OBJECTIVE AND PURPOSE OF POLICY
U.S. export control laws and regulations govern how certain commodities, information, technical data, technology, technical assistance, and research can be released to U.S. persons outside the U.S. and to foreign persons whether located in the U.S. or outside of the U.S. This policy is established to ensure full compliance with U.S. export control laws and regulations.
II. STATEMENT OF POLICY
It is the policy of UNF to comply fully with all applicable U.S. export control laws and regulations, including, but not limited to, the Arms Export Control Act ("AECA"), 22 U.S.C. §§ 2778-2994; the International Traffic in Arms Regulations ("ITAR"), 22 C.F.R. parts 120-130; the International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. §§ 1701-1706; the Export Control and Reform Act of 2018 (“ECRA”) , 50 U.S.C. §§ 4801–4852; the Export Administration Regulations ("EAR"), 15 C.F.R. parts 730-774; and Office of Foreign Assets Control regulations. Such laws and regulations include but are not limited to:
• Restrictions on transfers of export-controlled technical data, technology, software and services to foreign persons wherever located (including foreign person employees in the U.S.)
• Restrictions on exports and re-exports of certain hardware and equipment
• Restrictions on attendance at, or submission of papers to, foreign scientific conferences and journals and on travel to a foreign country
• Economic sanctions and embargoes against certain countries, terrorist/terrorism-sponsoring organizations, entities involved in the proliferation of weapons of mass destruction, international narcotics traffickers and "Specially Designated Nationals."
• Prohibitions on participation in foreign boycotts that the United States does not authorize.
The university community expects all individuals involved in scientific research and scholarly activity to comply with U.S. export control laws and regulations.
The University will fully comply with U.S. export control laws while ensuring that, to the extent possible, university instruction and research is conducted openly and without restriction on participation or publication. To this end, the University will ensure that, unless unavoidable, information generated during the performance of any university research, including sponsored research activities, qualifies for the Fundamental Research exclusions of applicable export control laws.
The civil and criminal penalties associated with violating export control regulations can be severe, ranging from administrative sanctions including loss of research funding to monetary penalties to imprisonment for individuals.
The University's Export Compliance Officers are responsible for ensuring implementation of this policy and related guidelines and serve as the primary contacts on export control matters.
III. STATEMENT OF PROCEDURES
The Export Compliance Website establishes the guidelines for complying with this policy.