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Export Compliance

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Background

The University of Washington is committed to compliance with federal laws and regulations governing exports and ensuring such compliance is consistent with the University's open academic environment that fosters intellectual creativity, freedom to carry out research in an unrestricted manner, and the open dissemination of research results.

All activities undertaken by our University community, including research activities, must comply with the export control regulations and University policies, procedures and standards already in place such as the University Presidential Orders on Classified, Proprietary and Restricted Research, UW's Information Security and Privacy Policies and Standards, and the Grants Information Memoranda (GIMs).

The Office of Sponsored Programs (OSP) manages the export compliance program for the University of Washington. OSP provides tools, resources and guidance on export control regulations and how to implement measures to ensure that projects or activities comply with these regulations.

It is the responsibility of University faculty, staff, officers, staff, and administration to be aware of the export control requirements under the regulations and the program administered by OSP.

The U.S. export control laws and associated regulations govern:

  • the release of technology, technical data, software, and information to foreign nationals within or outside the U.S.
  • the furnishing of defense services to foreign persons whether in the United States or abroad;
  • the shipment or other transmission of items or defense articles outside the United States; and
  • the ability to export or otherwise transact with certain individuals, entities and countries.

Certain export transactions require a license or other written approval from the U.S. government prior to export. Some transactions are prohibited due to the end-use, end-user, or country involved. These requirements are in place for national security, nuclear non-proliferation, regional stability, prevention of chemical and biological weapon proliferation and other foreign policy and security reasons.

Regulations

Federal export control laws and regulations control access of certain items, technology and software. These access controls are designed to protect the national security, foreign policy, and economic interests of the United States.

ITAR

International Traffic in Arms Regulations (ITAR), regulates Defense Articles, Defense Services and Technical Data. Any ITAR controlled item, service or technology would require an export license prior to export.

Examples of ITAR items:

  • Chemical Agents
  • Imaging Systems
  • Underwater Autonomous Vehicles
  • Items enhanced for a specific military use

EAR

Export Administration Regulations (EAR) regulates "Dual-Use" (commercial and military applications) and purely commercial; items, software and technology.

Examples of Dual Use items:

  • Composite Materials
  • Pathogens
  • Accelerometer

OFAC

The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces sanctions as well as embargoes of foreign countries, governments and regimes.

These lists are:

  • Comprehensive - Any Exports/Imports
  • Regime Based - Political Party/Gov't
  • Limited - Specific types of goods

More information on export regulations can be found here.

Technology Control Plan (TCP)

A Technology Control Plan (TCP) is an internal UW compliance document prepared by the Principal Investigator and approved by the Office of Sponsored Programs. It states the type of export-controlled information associated with a research project, measures to be taken by the PI to ensure access to the export-controlled information is managed and protected from unauthorized access.

A TCP is required when:

  • Projects or activities involve the receipt of Sensitive Unclassified Information (SUI) from an outside party or sponsor, such as via a nondisclosure agreement or sponsored research agreement;
  • Projects or activities are not considered Fundamental Research; or
  • Projects or activities involve technology and/or software associated with export-controlled equipment.

More information on a TCP can be found here.

Training

Want to learn more about export control laws and regulations or how to implement effective practices into your department? Please attend our next training offered to campus or contact exports@uw.edu to request onsite training. Online training in the form of a catalyst tool can be found here.

More information on training found here.

Resources

OSP provides various guides and tools for general use. Many of these documents or handouts can be found in this section including a glossary of export control terms. Federal and government links of export control laws, regulations and guidance can be found in this section as well.

More export compliance resources can be found here.