Individuals responsible for outgoing shipments from the University to end-user entities and individuals should be aware of export control regulations. If an item is export controlled by the U.S. Department of Commerce or the U.S. Department of State, there may be limitations on where the item can be shipped.
In addition to where the item can be shipped, there may be restrictions on who may receive the shipment. It is a best practice to implement a routine screening process of every receiving entity/individual against government restricted party lists, whether the shipment is within the U.S. or international. A consolidated list of restricted parties is available through the Consolidated Screening List, a list of all governmental agency restricted parties.
A recent penalty assessed against a University reflects how even what appears to be a benign shipment can lead to an export control violation. As detailed in the analysis of the case, a “low level” control on an item that is shipped to a restricted entity is a clear violation and leads to civil penalties and potentially criminal penalties.
Questions about export controls? Please visit the University of Washington’s export control website, click on the area of interest, and find out more. For more detailed assistance, please send your inquiry to firstname.lastname@example.org.