Training Program

Training is a critical component of maintaining compliance with export control and economic sanction laws. The primary goals of training are to increase awareness of and maintain compliance with export control laws and trade sanctions. The program educates the UMass Amherst community about its responsibilities under these laws and the UMass Amherst procedures for ensuring compliance. It is especially critical that faculty, administrative staff, and students who direct or participate in research projects involving export-controlled goods, technology or software participate in training provided through ORC. Further, federal agencies sponsoring research require export control training as part of their commitment to research security. The scope of training will depend on the nature of an individual’s or group’s exposure to export-controlled items and/or information, as well as any applicable federal agency requirements.

Training Topics

Training can include an overview of the purpose of export controls, how export regulations apply to different activities, review of definitions and regulations, the importance of compliance, description of the high-risk disciplines, and the types of exclusions, exemptions and exceptions that commonly apply. In addition, training can cover security measures that should be followed, steps to follow for physical exports, instruction on how to determine the CCL or USML designation of items, information about applying for a license, identification and reporting export control violations and red flags, internal review procedures, the importance of training, and the importance of utilizing the ORC as a resource.

The following introductory topics are among those that can be covered in faculty, staff, and student training:

• Purpose of U.S. export control laws and UMass Amherst Export Control Guidelines
• Regulatory agencies and statutes governing exports
• What is an export and what regulations might apply
• Deemed Exports and Foreign Nationals defined
• U.S. Munitions List and Commerce Control List
• General Prohibitions on End Use and End Users
• Physical exports
• Restricted-party screening of individuals and entities
• How to detect suspicious and inconsistent behavior (red flags)
• Protection of intellectual property / elicitation techniques
• Office of Foreign Asset Control Sanctions & Embargoes
• Fundamental research and educational information exclusions
• International visitors
• Examples of common license exceptions
• Identifying, documenting and reporting red flags
• Enforcement of violations and the severe sanctions and penalties which can apply
• Contacts for further assistance
• Questions and Answers

Advanced Training Topics for Faculty, Administrative Staff and Students can include:

• Contract language that restricts publication and personnel access
• Foreign sponsorship of research
• Nondisclosure agreements
• Materials transfer agreements with foreign entities or persons
• Teaching or training activities that use or implement licensed technology
• Foreign Corrupt Practices Act (for faculty assigned to teach oversees)
• Technology Control Plans

Department Training

Special efforts will be taken to ensure that all departments in high-risk disciplines (such as sciences and engineering) receive training. For example, training may be scheduled during department meetings or other times which are convenient for those departments.

Technology Control Plan Training and Briefings

One-on-one training will be provided by ORC to researchers who are involved in projects confirmed to involve export-controlled technology. The type of training, date, and who was trained is recorded and kept on file with the ORC.

Other Materials

While most training will be classroom style with opportunity for questions and discussion, additional information may be provided in the form of email notifications, institutional compliance newsletters and announcements, online training and information, and invited speakers. Useful materials and forms are available on the ORC website.

Training Options

Training can be scheduled by contacting ORC for one-on-one training at any time throughout the year. Online training about export controls in general is also available anytime via the CITI program.

Training Records

All records of training sessions will be maintained by the ORC for a period of at least five years. The records shall include date and place of training, sign-in sheets signed by persons attending (if applicable), list of speakers, and the subjects covered.