Record Keeping

UMass Amherst must comply with the various record keeping requirements of the EAR and ITAR and related laws and regulations. Record keeping to meet federal regulatory requirements is generally (and preferably) done by providing documents to the ORC, but in some instances involves offices or departments keeping documents locally and providing copies to ORC. For example, OGA maintains all international student and scholar records. Export control records that are retained and secured by ORC include any licenses, license applications, policies, manuals, forms and guidelines, memoranda, notes, correspondence, screens, contracts, invoices and other financial records, shipping documents including bills of lading and Automated Export System (AES) records, records submitted to ORC for vetting including exclusion and exemption analyses, certificates, audit/review check sheets and reports, and any export control clearance form. The software used for restricted-party screening, Visual Compliance, maintains a record of every search unless the search is specifically deleted. Training records are also retained by ORC and include sign-in sheets signed by persons attending, date and location of training, speakers, and the subjects covered. Records from other departments are requested periodically by ORC for audit/control purposes and to help evaluate the export control compliance program’s effectiveness. Records are maintained for a period of five years from the expiration date of the authorization or date an exemption is claimed. OFAC requires records be retained for ten years. Thereafter, the records should be discarded consistent with the UMass Amherst record retention policy.