The Research and Engagement executive area, through its Office of Research Compliance (ORC), has been charged by the Chancellor to recommend and implement a training program for the campus community on export controls—U.S. laws and regulations that regulate and restrict the release of critical technologies, information, and services to foreign nationals, within and outside of the United States, and foreign countries for reasons of foreign policy and national security.
Orientation and training in foundational aspects of export controls is critical to ensuring UMass Amherst faculty, staff, and students are aware of and can seek assistance with transactions or circumstances that may be impacted by export control laws and regulations. Because the export control regulatory schema impacts not only research activities, but also international travel, purchasing, shipping, receiving, and other aspects of daily university business, it is important that the campus community has a sufficient understanding to ensure compliance. Individuals who complete and maintain this training, and follow the relevant University policies and procedures, can rely on the University’s protections against liability and its continued support for their activities.
Because compliance with export controls is a legal requirement for both individual researchers and their institutions, the onus to understand and comply with the regulations is on both individual faculty and UMass Amherst. Department heads, because of their interaction with faculty, are positioned to play a critical role in ensuring understanding of export controls. The Chancellor’s Office and ORC strongly recommend that all faculty, staff, graduate students, and undergraduates involved in sponsored or international research take advantage of the following two export control training modules available through the Collaborative Institutional Training Initiative (CITI) program, which will provide familiarity and a basic understanding of export controls:
- Export Compliance for Researchers: Part I (ID: 16801)
- Export Compliance and United States Sanctions Programs (ID: 16812)
(Link to CITI Training: https://www.citiprogram.org/. Once there, click "Login via SSO," select "University of Massachusetts Amherst," and enter your UMass NetID and password. Further instructions are available on our Export Control homepage.)
Further, ORC staff is available to provide training to departments, through a short group presentation, and assist faculty individually with determining the applicability of export controls to their activities. ORC also supports the day-to-day analysis of transactions and activities for any export control compliance concerns in accordance with campus operational policies and guidance (see Export Control Program).
While the Chancellor’s Office is strongly suggesting that all faculty and staff and certain students take online training through the CITI program (see the Chancellor’s Memo on Export Controls dated September 19, 2016), this is critical for faculty, staff, and graduate students in high-risk areas, including Chemical Engineering, Electrical and Computer Engineering, Mechanical and Industrial Engineering, Physics, Chemistry, and Microbiology, which are more likely than other subject areas to involve export-controlled items and technical data. Further, faculty, staff, and students whose activities have been determined to intersect with export control regulations will be required to participate in training, either through the CITI program or provided by ORC staff, as a condition of approval for particular transactions or research activities. This training may include additional CITI training modules, such as Export Compliance for Researchers: Part II.
Export control regulations are complex and dynamic, and ORC can offer resources and expertise to help understand the application of the regulations to your university business. Should you have questions, or to schedule a presentation, please contact the Office of Research Compliance at (413) 545-5283 or via email at rescomp@research.umass.edu.
September 2016