UO faculty members who conduct research and other activities across international lines now have a new website to help them follow federal regulations that govern the transfer of items and information.
A memo outlining the issue and signed by UO’s chief research officer, David Conover, and chief financial officer, Jamie Moffitt, was distributed to deans and directors Jan. 25. The memo encourages UO faculty members to familiarize themselves with the regulations and pointed to a host of new resources available to UO faculty members, chief among them being the new website devoted to what are known as “export controls.”
“In the course of conducting research or traveling internationally, our faculty and staff may be subject to U.S. export control regulations,” the memo read. “Faculty and staff are required to demonstrate their due diligence and to document their adherence to U.S. export controls and trade sanctions laws when such laws apply.”
Export control regulations impose restrictions on access, dissemination or participation regarding the transfer of items and information regulated for reasons of national security, foreign policy, anti-terrorism or nonproliferation.
Because the regulations are extensive and not always obvious, the UO export controls website includes a decision tree questionnaire to determine whether export controls are applicable to a particular project. The site also has a list of controlled items, definitions of relevant terms and links to an online training module.
Export control regulations can affect everything from transferring physical items, computer software and technical information — whether involved in teaching, research, service or international travel — to attending or participating in a conference involving a sanctioned U.S. country, such as Iran, North Korea, Syria, Cuba, Sudan and the Crimea Region/Ukraine.
The message circulated on Friday also noted that individuals and institutions found to be involved in export control regulation violations can be prohibited from engaging in future activities. The memo cited a few real-world examples that demonstrate what can happen when export control regulations aren’t followed and underline the importance of adhering to the regulations:
- At the University of Michigan, a research fellow shipped an MRI coil to Iran without a license. The research fellow was not aware he needed it, but even without demonstrable intent, the research fellow was criminally prosecuted for the shipment and subjected to civil penalties as well.
- At the University of Tennessee, John Reece Roth, a former professor of electrical engineering, served four years in prison for committing conspiracy, wire fraud and 15 counts of exporting “defense articles and services” without a license. Among other violations, Roth unlawfully traveled to China with a laptop containing sensitive Department of Defense files and employed an Iranian and a Chinese graduate student in his lab without securing the required federal licenses.
- At the University of Massachusetts at Lowell, researchers exported an atmospheric sensing device, antennae and cables valued at slightly more than $200,000 to Pakistan’s Space and Upper Atmosphere Research Commission. Because the university did not secure a license for the shipment to the Pakistani commission — which is on the bureau’s entity list of individuals, businesses and government and private organizations that are subject to licensing requirements — the university was fined $100,000.