Fayetteville Policies and Procedures 206.7
Export Control Compliance
The following is the policy of the University of Arkansas, Fayetteville (hereafter referred to as the University) regarding compliance with U.S. export control laws and regulations. It applies to all University research, teaching and business activities and to all employees and other persons acting as representatives of the University, including at off-campus locations.
- The University is committed to complying with all U.S. laws and regulations pertaining to the export of items, services, and technology. Regulations applicable to University activities include the Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR); and sanctions programs administered by the Office of Foreign Assets Control (OFAC). Other federal agencies, including but not limited to, the Nuclear Regulatory Commission (NRC), Department of Energy (DOE), Bureau of Alcohol, Tobacco and Firearms (ATF), Food and Drug Administration (FDA) and Drug Enforcement Agency (DEA) may also regulate the export or transfer of certain items and technologies.
- Export control restrictions can apply to actual export of restricted items, material or information outside of the U.S., or to the deemed export of restricted information through access to such information in the U.S. Export control restrictions may apply to specific countries or prohibited individuals or entities.
- Certain academic activities that meet specific criteria are exempt from control. Fundamental Research, published information, and information released by instruction in University catalog courses or associated teaching laboratories (as described by the regulations) are generally exempted from U.S. export controls. The Fundamental Research Exclusion applies only to the dissemination of research data and information, not to the transmission of material goods. Restrictions on publication of research results or personnel access restrictions may invalidate the Fundamental Research Exclusion.
- Those engaged in research activities involving potentially restricted material or information, operating research facilities, hosting international visitors, or engaging in or administering international travel on behalf of the University, are expected to maintain familiarity with applicable restrictions and best practices in this area.
- The Director of Research Compliance, under the direction of the Vice Chancellor for Research and Innovation, shall oversee the University’s compliance with U.S. export control laws and regulations and shall have primary responsibility for ensuring that this Policy is properly implemented and followed. The University’s export control officer shall furnish training to relevant faculty and administrative personnel whose work may be impacted by these regulations and provide technical assistance regarding compliance, as well as assisting with federal agency requests for export licensing as required. University employees and others acting on the University’s behalf are responsible for ensuring that activities are conducted in compliance with U.S. export control laws and regulations.
- Failure to comply with applicable export control laws and regulations may lead to civil and criminal penalties, as well as to disciplinary actions under University policies.
Approved September 9, 2019