To address the campus’ obligations to comply with federal export controls.
This policy applies to all members of the campus community, including but not limited to employees, tenure- and non-tenure-track faculty, lecturers, students, postdoctoral fellows, postdoctoral scholars, and other postdoctoral personnel, independent researchers, visiting scholars, visiting scientists, contractors, subcontractors, and volunteers.
Vice Chancellor for Research
Federal export controls impact many activities on campus. These activities include, but are not limited to, researching, purchasing, acquiring, and/or developing items, technologies and information subject to export controls; research, employment, and academic activities involving Foreign Persons located within or outside the United States; the transfer, shipment and/or distribution of equipment, technology, or software outside the United States or with Foreign Persons wherever located; and international travel. Export controls may prohibit engaging in these activities altogether or may require obtaining a license or other governmental authorization prior to engaging in these activities.
All members of the campus community shall comply with applicable federal export control laws and regulations, including without limitation the Arms Export Control Act (“AECA”), 22 U.S.C. 2751 et seq.; the International Traffic in Arms Regulations (“ITAR”), 22 C.F.R. 120 et seq.; the Export Administration Regulations (“EAR”), 15 C.F.R. 730 et seq.; the Foreign Assets Control Regulations (“FACR”), 31 C.F.R. 500 et seq.; and all campus policies and procedures related to export controls.
Research and other activities subject to export controls, or involving items and information subject to export controls, are generally allowed, provided that members of the campus community seeking to engage in these activities conduct them in compliance with, and abide by, the above-referenced laws and regulations, this policy and any procedures established by the Export Compliance Officer, and other university and campus policies, and any procedures established by other academic or administrative units with oversight over such activities. Allowed activities include, but are not limited to: researching, purchasing, acquiring, and/or developing items, technologies and information subject to export controls; accepting restrictions on the publication of the results of, or participation by Foreign Persons in research; international travel (including travel to embargoed countries); and collaborations with Foreign Persons, wherever located.
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment. Failure to comply with export control laws and regulations may additionally result in civil or criminal penalties and reputational harm for individuals and the university.
The Chancellor will appoint at least one employee to serve as an Empowered Official for ITAR. At his or her discretion, the Chancellor may appoint more than one person to serve as an Empowered Official for ITAR. The employees appointed as Empowered Officials for ITAR may either share responsibility for all campus activities, or the Chancellor may divide responsibility for campus activities separately among the Empowered Officials for ITAR. Pursuant to 22 C.F.R. 120.25, an Empowered Official for ITAR has the following authorities and responsibilities that may not be delegated:
The Chancellor has directed the Vice Chancellor for Research to develop and implement policies and procedures regarding the campus’ export control obligations. The Vice Chancellor for Research has delegated responsibility for the ongoing development and maintenance of these policies and procedures to the campus Export Compliance Officer. The Export Compliance Officer’s responsibilities include:
Researchers (including tenure- and non-tenure-track faculty; lecturers, postdoctoral fellows, postdoctoral scholars, and other postdoctoral personnel; independent researchers, students engaged in research; and visiting scholars) bear the primary responsibility for complying with export controls in the conduct of research and other activities in which they participate. Specifically, researchers are responsible for:
Academic and administrative units are responsible for developing, in consultation with the Export Compliance Officer, procedures for complying with this policy and export controls.
The campus procedures for complying with export controls, the Export Control Compliance Procedures and important contact information are available on the campus’ Export Compliance website, http://research.illinois.edu/regulatory-compliance-safety/policy-export-control.
For more information regarding exports, refer to:
There are no exceptions to this policy.
Export Compliance Officer, firstname.lastname@example.org