From the Office of the Chancellor (11/30/22)
To the Campus Community:
The Office of Research Compliance (ORC) maintains, updates, and implements UMass Amherst's policies and procedures regarding U.S. export controls under the direction of the Vice Chancellor for Research and Engagement. This memo reintroduces campus export control policies and procedures and provides basic information about export controls and resources available to help comply with them.
Export controls are U.S. laws and regulations that restrict the release of certain items, information, and services to foreign nationals, within and outside of the United States, and foreign countries for foreign policy and national security reasons. These laws and regulations, which include international sanctions programs, also restrict activities within certain countries and with designated institutions, entities, and individuals, even if no controlled items are involved. Among the sanctioned countries, the following are currently subject to comprehensive sanctions programs: Cuba, Iran, North Korea, Syria, and the Russia-occupied regions of Ukraine. Any potential University-related activities in or with parties in these countries require advance consideration by and planning with ORC. Export controls, given their purpose, are subject to frequent additions and amendments responsive to rapidly-changing international affairs.
The term “export” is defined broadly within U.S. export controls and includes, but is not limited to, releasing identified items and information to foreign nationals within the U.S. UMass Amherst’s Export Control Compliance Program Guidelines, training materials, resources, and guidance on the laws and regulations are available on the ORC export controls website.
It is the responsibility of all campus community members to be familiar with and adhere to the requirements of export control regulations. Individuals and institutions that violate federal regulations governing export-controlled activities may be subject to civil and criminal penalties that can include significant fines, jail terms, denial of export or research privileges, and debarment from government contracting.
Because of the broad scope of export-controlled items, which include, but are not limited to, equipment, software code, chemical and biological materials, and technical data, these laws and regulations apply to virtually all fields of science and engineering and restrict both physical shipments and electronic transmission of information. Further, country-specific sanctions programs and party-based restrictions apply regardless of research subject matter. Export control laws apply to all activities—not just sponsored research projects.
University of Massachusetts policy requires compliance with all U.S. export control laws and regulations, which apply to both researchers individually and their institutions. Therefore, all faculty, staff, graduate students, and undergraduates involved in export-controlled research are required to have training before beginning those projects. Further, it is strongly suggested that all community members involved in sponsored or international research take advantage of two export control training modules available through the CITI program:
- Export Compliance for Researchers: Part I, and
- Export Compliance and United States Sanctions Programs.
For more information visit the Export Control Training Program website. Should you have questions, or to schedule training on the application of export controls to your research area, please contact Ellie Kurth in the Office of Research Compliance.