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February 22, 2011 | Imagine that you’re about to send a foreign colleague a link to download a data set on which the two of you are collaborating. Or maybe your colleagues from abroad are visiting NCAR and you decide to gift them with a piece of research equipment. Although these exchanges sound innocuous, they are considered “exports” by the U.S. government and could possibly be subject to regulation.
Because U.S. export laws and regulations can be confusing, UCAR has launched a program to ensure that the organization and its staff are in compliance. Jeff Reaves and David Sundvall in Business Services are coordinating the effort, and each lab and/or division has an appointed export compliance coordinator (ECC). In addition, UCAR’s Office of Legal Counsel provides support as needed.
“Our goal is to create awareness of what export compliance means throughout the organization and make sure that staff understand that it’s the responsibility of each individual to comply,” David says.
Since September 11, 2001, government scrutiny of exports has increased, David explains. Whereas in the past export controls were aimed mainly at large companies in the defense industry, today research institutions and nonprofit organizations are being found in violation of the laws with greater frequency.
The U.S. government strictly regulates all exports of U.S. products, technology, and software, such that any item sent from the United States to a foreign destination is considered an export. This includes items that leave the United States only temporarily and those that leave but are not for sale, such as research equipment (including aircraft). Even items of foreign origin exported from the United States and those being returned to their countries of origin from the United States are considered exports. If technology or source code subject to export regulations is released to a foreign national in the United States, it is deemed to be an export to the home country of that foreign national.
How an item is transported outside of the country does not matter in determining export license requirements; for example, an item could be sent by regular mail or hand-carried on an airplane. A set of schematics can be sent via fax to a foreign destination, software can be uploaded to or downloaded from an Internet site, and technology can be transmitted via email or telephone.
The UCAR Export Compliance Program serves to assist staff involved in the export of items and technical data. The goal is for the ECCs, who will work closely with David and Jeff, to function as “go-to people” versed in the particular export issues of their respective labs and divisions. HR offers export compliance classes twice yearly, and David is available for special sessions by request.
Staff are encouraged to visit the UCAR Export website, where a list of frequently asked questions and other information is available. They can also contact their group’s ECC, listed on the website, as well as Jeff Reaves (ext. 8890), or David Sundvall (ext. 8898).