Detecting and Reporting Violations

Commitment to Reporting

An integral part of export compliance is that employees report suspected violations of export laws and these suspected violations are thoroughly investigated. It is the policy of UMass Amherst to voluntarily self-disclose violations as required. Members of the UMass Amherst community are expected to contact the ORC should they have any questions about the application of the export control laws to their research or other activities. UMass Amherst faculty, administrators, staff, and students should report any potential violations to the ORC. No employee shall be punished on the basis that he or she reported what was reasonably believed to be an act of wrongdoing or a violation of the export control laws.

Investigation

Once an alleged violation has been reported, an investigation will be initiated to determine the validity of the allegation and an appropriate response. If the allegation merits further fact finding and investigation, ORC will work with the appropriate parties to conduct a thorough investigation. The results of its investigation are then made known to senior management to consider further action, including notification of the appropriate government agency, and taking corrective action. All documents and records relating to any suspected violation must be immediately secured and maintained in accordance with all applicable record keeping requirements. Information Technology and Campus Police support these investigations as needed.

Government Subpoenas

In the event any subpoena or other request for documents is received from any Federal agency, immediately contact the UMass Office of the General Counsel. Likewise, if a federal agency representative arrives on campus for a non-routine activity, immediately contact the Campus Police and the Office of Research Integrity for assistance. You shall not interfere with or obstruct any federal agent or law enforcement officer in the performance of his/her duties.