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Implementation of a University Export Compliance Management Program. Adilia F. Koch. Export Compliance doesn’t come cheap. It’s the price of doing business in the international arena.

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export compliance doesn t come cheap
Export Compliance doesn’t come cheap.
  • It’s the price of doing business in the international arena.
  • Price of non-compliance can result in negative publicity, put your endowment at risk, result in penalties & fines –
    • $250,000 to $1,000,000
    • Criminal offenses can result in imprisonment
export compliance management program where do you start
Export Compliance Management Program: Where do you start?
  • Risk Assessment
    • Should be conducted under the direction of your Office of General Counsel to invoke the “Attorney-Client Privilege” and “Attorney Work Product” protection.
    • Identify most likely areas of high risk on campus:
      • Sponsored Research
        • Problematic Clauses
        • FRE language may be jeopardized
      • Procurement
        • Potential exports of technology with RFP or RFQs (foreign procurements)
      • Mailing and/or Shipping & Receiving
        • Export of hardware, software or technology
best practices
Best Practices
  • Work with the process owners in developing best practices
  • Start with the higher risk areas
  • Conduct frequent assessments and audits to make sure its working
  • Outreach conduct campus process owner visits to work out the kinks
be ready to implement stop measures right away
Be ready to implement stop measures right away.
  • Once you become aware of potential areas of high risk, you will need to implement changes as quickly as possible to minimize the exposure.
  • Seek legal advice.
  • Violations? Disclosures? The folks in the Office of General Counsel will be your new best friends.
  • Have your wallet ready. . . you may also need to seek outside counsel.
awareness training
Awareness Training
  • Conduct Awareness Training
    • Group Sessions
    • One-on-one with faculty, if necessary
    • On-line training
  • Use various media’s depending on what works best for your campus and budget
assessment audit is your program working
Assessment & Audit: Is your program working?
  • Don’t write a process or procedure you cannot implement
  • Internal audit review --- thumbs up!
  • Conduct regular assessments to ensure program is working
    • Audit vs. assessments --- they’re not the same
resources
Resources
  • Nunn-Wolfowitz Report
  • Export Compliance Management Program - BIS Seminar
contact
Contact

Adilia F. Koch

Director of Export Compliance

California Institute of Technology

contact info
Contact Info

Adilia F. Koch

Director of Export Compliance

California Institute of Technology

adilia.koch@caltech.edu

Phone: (626) 395-4469

Fax: (626) 795-4571