Policy on Export Controls
All University personnel (including faculty, staff, visiting scholars and students) who plan to ship or even to hand-carry out of the country any research equipment, biological material, or nonbiological scientific samples are required to contact Aaron Gunsalus, Interim Export Compliance Shipping Specialist (ph: 919-962-5709, firstname.lastname@example.org) several weeks before the date of transport to get the help you need to make sure you do not run afoul of export control regulations. Transporting any amount of regulated material in an aircraft, either on your person, in carry-on luggage, or checked luggage is covered by export control regulations.
It is each employee’s responsibility to understand export control requirements related to his or her work and to ensure that no exports are made contrary to any of these regulations. These regulations have significant potential applications in travel, research, transfers of material or equipment or information, purchasing, surplus property, and contracting. The University has established a program to provide information and practical operational assistance on export controls compliance. University personnel need to recognize potential export control issues and to avail themselves of the applicable University support services listed below for assistance complying with these regulations.
- Export Controls and Transfers of Material, Equipment, Supplies and Technologies: Help is available online at http://ehs.unc.edu/biological/ec/#general and also by contacting Aaron Gunsalus, Interim Export Compliance Shipping Specialist (ph: 919-962-5709, email@example.com).
- Export Controls and International Travel: Help is available online at http://ehs.unc.edu/biological/ec/#travel and also by contacting Judy Faubert, Associate University Counsel (ph: 919-962-7483; firstname.lastname@example.org).
- Export Controls and Research: Help is available online at http://ehs.unc.edu/biological/ec/#export and also by contacting Judy Faubert, Associate University Counsel (ph: 919-962-7483; email@example.com).
- University Export Control Webpage: http://ehs.unc.edu/biological/ec/
Export control regulations are detailed and complex. Their application is defined both by the content being transferred and by the transfer destination, and both factors extend beyond what is intuitive. The materials and equipment potentially covered by export controls sometimes have no obvious commercial or military value, and the restricted destinations include many of the closest allies of the United States. Export control regulations also apply to certain transfers of technical information and money outside the United States.
Failure to comply with these regulations can result in severe civil and criminal penalties for both the employee moving the item/information out of the country and for the employee’s institution. Researchers at other universities and other individuals who have violated these laws have received jail sentences and heavy fines.
It is the policy of the University of North Carolina at Chapel Hill that all personnel, including employees, visiting scholars and students comply with all United States export control laws and regulations, including the Department of Commerce’s Export Administration Regulations (EAR), the Department of State’s International Traffic in Arms Regulations (ITAR), and the regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC).
It is also University policy that its instruction, research and public service missions will be accomplished openly and without prohibitions on the publication and dissemination of the results of academic and research activities, subject to the University’s classified research policy (http://policies.unc.edu/policies/classified-research/). For this reason, it is vital to avoid actions which may eliminate the University’s ability to use exclusions in the export control regulations that protect the University’s performance of research and teaching.
Policy Effective Date: October 1, 2007