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Export Management

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Export Management

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    1. Export Management Matt Ronning

    2. Control is Misleading What is an export? Why do we care? How can we “control” them? Who is in charge? Where is the risk?

    3. What is an Export? Well, anything sent abroad or otherwise made available to a non-citizen/permanent resident on US soil. Hmm, I’m starting to understand the use of the word “control” now… A controlled export is …

    4. Controlled Export Transfers of controlled information, including technical data, to persons and entities outside the United States; Shipment of controlled physical items, such as scientific equipment, that require export licenses from the U.S. to a foreign country; Verbal, written, electronic, and/or visual disclosures of controlled scientific and technical information related to export controlled items to foreign nationals (“deemed exports”) in the United States.

    5. What is controlled? EAR, ITAR, OFAC EAR Inherently Commercial but military too… 0—Nuclear Materials, Facilities and Equipment, and Miscellaneous 1—Materials, Chemicals, Microorganisms, and Toxins 2—Materials Processing 3—Electronics 4—Computers 5—Telecommunications and Information Security 6—Lasers and Sensors 7—Navigation and Avionics 8—Marine 9—Propulsion Systems, Space Vehicles, and Related Equipment

    6. What is controlled? International Traffic in Arms Regulations (ITAR) Defense Articles Defense Services Office of Foreign Asset Control (OFAC)

    7. Good News No license is required for export of: (1) Information arising during or resulting from fundamental research. (2) Data released orally or visually at open conferences, lectures, other media open to the public. (3) Publications that may be purchased without restrictions at are readily available at public libraries. (4) Patents available at any patent office. (5) Dissemination of educational information by instruction in and associated laboratories in academic institutions.

    8. More Good News Fundamental Research might get us out of needing an export license… UNC BOG has a policy of open publication Ah, but they’ve left a loophole so be very careful. Plug that loophole with consistency and process.

    9. How do you plug the hole? Process, Consistency, Training, Networking, Planning… But don’t go overboard! Assess where you are; admit your short comings; engage a consultant; have a briefing; get to know your local federal agents…

    10. What is NC State doing? Everything right, bank on that…

    11. Develop Resources

    12. Avoid a Train wreck Briefings from NCIS, FBI, DoC, DSS 3 in last 12 months Find training and pay to go to it 2 of us went to Boston, 1 to Chicago and 1 to San Francisco Have staff meetings We’ve afforded this topic as much as we afford publication rights, IP matters, human and animal subject debates and then some. Create metrics to follow – steal them from other universities as a starting point if you have to.

    13. Avoid Trouble

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