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The purpose of this policy is to state the essential aspects of the laws and regulations concerning exports, confirm our policy for compliance, and explain how the University will provide our researchers with the assistance they may need to ensure compliance with these complicated laws.

II. ACCOUNTABILITY

Under direction of the President, the Vice President for Research and the Research Compliance Officer shall implement and ensure compliance with this policy. 

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1. Rowan University (RU) is fully committed to complying with applicable export control laws. To ensure compliance with these laws, Institution's projects and programs will be managed in accordance with applicable Federal laws, rules and regulations as well as enumerated in this policy. These govern to the extent of any inconsistencies with the Institution's Information and Guidelines on United States Export Control Laws dated 6/10/2004 (See Attachment B), which also apply.

2. Research and inquiry into intellectual areas of great promise is one of the most basic obligations Rowan University has to its faculty, to its students, and to society at large. Rapid advances in the fields of science and engineering have resulted in a closer association between the university and industry. This close association in rapidly advancing technical fields often involves export controlled information, materials and technology.

3. As a general policy, RU will not undertake, on the campus, classified research or research whose results may not be published without prior permission. However, there may be situations in which the pursuit of knowledge may involve critically important, but sensitive areas of technology where the publication of research results would not be in the best interest of national security and public interest. In such cases, the University will have flexibility to depart from the standards of freedom of inquiry in order to serve public interest.

4. Rowan University is committed to the highest level of compliance with all applicable export control laws and regulations that pertain to the conduct and dissemination of our research and to the export of tangible items such as equipment, components or materials. While our primary mission is education, research and dissemination of knowledge, the responsibility remains to balance the service of this mission with safeguarding national assets through adherence to the export regulations, rules and laws of our country.

5. As a public institution of higher education, RU employs foreign nationals; collaborates with international partners on research, education and services; and hosts foreign visitors and international students in connection with international exchange programs as well as other academic, research and collaboration agreements. It is the intent of the Institution to employ foreign nationals, collaborate with foreign nationals and host international visitors, both long and short term, in the most welcoming manner possible while also assuring compliance with U.S. laws and regulations governing the export of certain items (including such items as equipment, software, chemicals, and biological materials) and technical data.

6. Most activities on campus will not trigger export licensing requirements and will be eligible for exclusions under the fundamental research exclusion, the publicly available or public domain information exclusion, or the educational exclusion. For those activities that are not eligible for such protections, each employee is personally responsible for safeguarding export?controlled data/information, i.e. controlled technology or technical data, as required by the above federal agencies from disclosure to foreign persons without prior approval. An export license from the U.S. government or determination by the RU's Office of Research that an export license exception or exemption is available is required before a foreign person or foreign national may be given access to items or technology/technical information controlled by either the U.S. Department of Commerce, the U.S. Department of State or the U.S. Department of Energy. No release of classified information (i.e. confidential, secret, top secret) is permitted to any person without the proper security level clearance and a documented "need to know" for that specific information.

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1. In 2013, the State of New Jersey designated Rowan as second comprehensive public research institution in the State of New Jersey. As a research institution and a U.S. institute of higher education, most research, teaching, or service at the Institution will appropriately fall under the fundamental research exclusion, the publicly available/public domain exclusion, the education exclusion or a combination of the three. There may be occasions in which RU may conduct research or provide service or agree to a contract with a sponsor involving classified research. In such cases, RU will have the flexibility to depart from the standards of freedom of inquiry in order to serve public interest. When such exceptions occur, each project will be reviewed by the Senate's Research Committee (SRC) and acted upon in light of its impact on overall research mission of the university.
2. Export Control Compliance Organizational Structure
1. The University's export compliance efforts will be coordinated through the Office of Research with the assistance of the Office of the General Counsel. However, much of the responsibility for export compliance lies with individual university personnel. The purpose of this section is to outline the university's export compliance structure.
2. RU's Export Control Compliance Review Team (Team) is comprised of the Vice President for Research, General Counsel or designee attorney ('GC'), Chief Research Compliance Officer, Director of Sponsored Program, Biological Safety Officer, Grants Specialist, Chief Internal Auditor, Director of Purchasing, Director of Asset management, Director of Technology Commercialization and Licensing and Director of Tech Park.
3. Vice President for Research will lead the Team and he/she is RU's empowered official for export controls. The Team is in place to ensure that the Institution has the infrastructure, resources, policies and guidelines to comply with all institutional compliance issues associated with Export Controls and Rowan University's Export Control Compliance Program.
4. The empowered official, GC and Chief Research Compliance Officer are knowledgeable in EAR, OFAC, AECA, DOE 10 CFR Part 810 ('DOE'), NRC 10 CFR Part 110 ('NRC'), and ITAR. Further, these individuals are cognizant of when and how these regulations affect the organization.
5. As part of Institution's Export Control Compliance Program, the Compliance Review Team has either initiated the internal controls to ensure compliance with EAR, OFAC, AECA, and ITAR or they have put together the appropriate teams to establish and implement the necessary export control compliance program. The Empowered Official has the approval authority for activities requiring export licensing, export licensing itself, and related security plans.
6. The departments and or divisions involved in export controls related to ITAR, AECA, OFAC, DOE, NRC, and EAR have devoted personnel to the Institution's Export Control Team and other resources to ensure compliance with the Federal rules, regulations and statutes. The other resources include funds to support training in export controls and procedures for screening and conducting following compliance functions.
1. Restricted parties screening;
2. Locating Federal Regulations on export controls;
3. Searching the Export Control Classification Number (ECCN) and (United States Munitions List (USML); and
4. Assisting in license determinations.
7. Asset Management Division, Purchasing Services and Environmental Health and Safety have implemented processes to track equipment, property (both Institution's titled and Government furnished), biologicals, chemicals and other materials that are controlled by ITAR, NRC and EAR.
3. Rowan University Export Control Working Group
   Membership in the Rowan University Export Control Working Group appears in Attachment 3.
4. SCREENING
   The following screens are performed or coordinated by the Export Control Coordinator as a procedure in the review of export control issues on campus. See Attachment 4.
1. Export-related Restricted, Denied and Blocked Persons Lists (BIS)
2. Sanction Programs Related Blocked Persons Lists
3. Law Enforcement –related Wanted Persons List (Domestic)
4. Politically Exposed persons and Office of Inspector general
5. International Terrorist, Blocked Person, Wanted, and Entity Lists
6. Export Risk Country Alerts
5. TRAINING AND EDUCATION
   See Attachment 5.
6. IDENTIFICATION, RECEIPT AND TRACKING OF EC ITEMS
   Office of Research reviews the scope of work from research project submissions, awards and contracts for export control related issues or materials. If this initial review reveals items of concern an Export Control Checklist is completed and/or discussions with the Principal Investigator (PI) are initiated to make further determinations as to the involvement of export controls. The Division of Research Compliance (DRC) in the Office of Research reviews and maintains in the award files copies of the proposals, research grants, contracts, confidentiality agreements and other agreements, as applicable, that may impact the export control review and determination. Additionally, Office of Research will perform export control review and license determination with the PI development of a Technology Control plan and/or interpretation of any EAR/ITAR export license requirement and associated documents, as applicable, pertaining to the project/research. Additionally, Office of Research is responsible for determining the need for licenses and submitting applications. When chemicals or biological materials are involved the Director of EHS and Biological Safety Officer will also review with the PI export control issue pertaining to the project.
7. IDENTIFICATION OF ITAR/EAR CONTROLLED PROJECTS REVIEW PROCEDURES
1. Office of Research has oversight and approval of all licensing under export control laws (with the exception of physical exports of biologics, chemicals and explosives out of the United States or OFAC travel related licensing). Office of Research also makes determinations relating to the export control status of new technologies and materials resulting from university research when an invention disclosure or a work disclosure has been submitted to the Office of Technology Licensing.
2. Division of Sponsored Research will review at the time of award all grant and solicitations, proposals, confidentiality agreements, awards, etc. for the following:
1. Restrictions on publishing research results.
2. Restrictions on foreign nationals from performing or accessing research results.
3. Restrictions on deliverables or results from being disclosed or delivered to any country or individuals.
4. Physical items being shipped overseas.
5. Verification that the project does not consist of basic or applied research.
6. RU Export Control Compliance Program.
7. The research effort is being conducted outside of the United States.
8. Embargoed/sanctioned countries and/or entities involved.
9. Scope/Agreement/Solicitation references weapons, select agents (aka highly pathogenic/toxic biologics), pathogens, toxins, bacteria, military systems, missiles, satellites, space related technologies, infrared, night vision, inertial measurement units (IMU), Global Positioning System (GPS), High Performance Computers (HPC), Astronomical Instruments (build/design main issue), armor, weapons of mass destruction, detectors, sensors, lasers, directed energy, trajectory, radars, cloaking, encryption, unmanned aerial vehicles (UAV), autonomous underwater vehicles (AUV), autonomous ground vehicles, optics, etc.
10. Requirement to use third?party information that is subject to nondisclosure obligations
11. Presence of export controlled items, data, or technology.
12. Other Red Flags are identified.
13. Upon completion of review, the final determination on whether or not the effort is controlled are made and determine if further steps need to be taken. If one or more of the above bullet points apply, then neither the fundamental research exclusion nor publicly available/public domain exclusion apply and Office of Research will assist the principal investigator in determining whether a controlled technology/commodity is involved and/or export control regulations apply to the project. DRC, UFIC and EHS are responsible for export licensing under their purview but will involve each other and additional offices as appropriate. To assist in making this determination, the principal investigator shall work with Office of Research RU's to follow RU Export Control Compliance Program.
8. OBTAINING AN EXPORT LICENSE
   If it is determined that a controlled technology or item is involved and an exclusion or license exemption does not apply; a license is required before the technology or item can be shared, disseminated, or exported out of the U.S.. This requirement applies to both research results as well as tangible items if the results are not covered by Fundamental Research, Public domain/Publicly Available Information, or other exclusions. The processing time for a license is normally two to four months after the application is submitted. Office of Research in conjunction with GC, will obtain any necessary ITAR, EAR and/or OFAC licenses.
9. ADMINISTRATION OF THE TCP
1. Administration of the TCP associated with any grant, proposal, or project is the joint responsibility of Office of Research and the PI/Department as it applies to the release of controlled technical data or items subject to the regulations whether in the U.S. or abroad.
2. Principal Investigators and department heads are responsible for ensuring that employees in their activities are properly instructed in the handling of classified, export?controlled, or proprietary information and that they have signed the required attachments, prior to involvement in the project, attended mandatory Export Control Training, and are cognizant of their obligations and responsibilities under the Project?specific TCP, as applicable.
10. TRAVEL AND PRESENTATION PROCEDURES FOR SANCTIONED/EMBARGOED ENTITIES
    Each employee is personally responsible for complying with travel, business, and export control restrictions relating to countries and individuals sanctioned by the United States in regulations, laws, and executive orders enforced by OFAC. For further information, individuals may contact Office of Research.
11. RECORDKEEPING
    The university is subject to several regulatory recordkeeping requirements related to its export activities. The ITAR and the EAR require that records be kept reflecting the export and temporary import of defense articles, defense services, dual-use commodities and related technologies. This procedure outlines requirements for complying with the recordkeeping regulations. Types of records to be maintained will depend on the university's activities and how items are controlled for export. The retention period is five years from the date of export, re-export, or any other termination of the transaction
1. Transactions subject to recordkeeping requirements
   The following types of transactions are subject to recordkeeping requirements:
   1. Exports of controlled commodities, software or technical data from the United States or by U.S. persons;
   2. Re-exports or transshipments of controlled products or technical data originally exported from the United States or by U.S. persons;
   3. Any other transaction subject to export control, whether the export or re-export actually occurs;
   4. Negotiations in connection with an export; and
   5. Exports, where it appears that a person in another foreign country has an interest in the transaction or that the commodity or technical data will be exported, transshipped, or diverted.
2. Records required to be kept
1. All documents related to export activities should be retained, whether they involve the administrative processes associated with obtaining licenses or other approvals, or the implementation of a license or approval, which has already been approved. It is RU policy that the following export documents and related supporting materials be retained by the University:
1. Any paperwork detailing internal export control assessments, including any documentation regarding the applicability of any licensing exemptions (such as public domain or fundamental research);
2. Include records of the compliance program, implementation efforts, and the steps to discover and rectify inadequacies. Such steps may mitigate the consequences of unintentional violations. Encourage prompt disclosure of potential violations to the central office for a knowledgeable and timely response including appropriate self-disclosure to the appropriate agency to mitigate penalties. Example: in an Export Control Management Plan Classification decisions issued by the appropriate government agency;
3. License applications, and all supporting documents;
4. Issued licenses with limitations or provisos, if any;
5. International Import Certificates and applications therefore;
6. Delivery Verification or similar evidence of delivery;
7. Shipper's Export Declarations ("SED");
8. Receipts, bills of lading and other documents related to export clearance;
9. Reports of boycott requests and all documents relating to the requests;
10. Any other document issued by the U.S. Government that demonstrates that an export occurred;
11. Applications for registration;
12. Purchase orders;
13. Foreign import certificates;
14. Airway bills;
15. Non-transfer and use certificates.
2. Memoranda, notes, correspondence, contracts, invitations to bid, books of account, financial records, and any other written matter pertaining to an export.
3. Period of retention
   Export documents must be retained for a minimum period of five (5) years, calculated from one of the following points in time:
1. Export records under the EAR (See §762.6) must be retained for five (5) years from the latest the following times:
1. The date the export from the U.S. occurs;
2. The date of any known re-export, transshipment, or diversion of such item;
3. The date of any termination of the transaction, whether contractual, legal, formally in writing or by any other means, or
4. In the case of records of or pertaining to transactions involving restrictive trade practices or boycotts, the date the regulated person receives the boycott-related request.
2. Records relating to exports under the ITAR must be maintained for five (5) years from:
1. The expiration of the license or other approval to which the documentation relates;
2. The date the license or other authorization is exhausted or used completely; or
3. The date the license or other authorization is suspended, revoked, or no longer valid.
4. Identifying Responsible Recordkeeping Function
   The University will maintain the following records, either originals or back-ups, through the Coordinator, Export Control, and Office of Research/Sponsored Programs.
5. Accessibility
1. Records must be kept in a manner which facilitates the ability to retrieve the records for any purpose and to review the records during internal or U.S. Government audits.
2. University Personnel may not, under any circumstances, interfere with or impede any federal law enforcement officer performing his/her official duties.
12. INTERNAL MONITORING/AUDITS
1. RU is committed to ensuring that its efforts to comply with United States export laws and regulations are successful and effective throughout the University. Every compliance program must include an internal assessment function designed to objectively and independently review all aspects of the program. RU will conduct internal assessments as required.
2. Each project which has a Technology Control Plan (TCP) will be reviewed on an annual basis. The PI, key persons and all labs/offices/etc. associated with the TCP will be visited and reviewed for compliance with the TCP. Any deficiencies will be noted and corrected. If there are substantial deficiencies the project may be halted pending correction of the deficiencies.
3. Types of Assessments
   1. Policies and Procedures Assessment - A review of policies and procedures will be conducted to assess whether the University effectively maintains export policies and procedures. This review is designed to identify whether applicable legal obligations are addressed throughout RU
   2. Self-Audit/Internal Audit - Regular internal audits should be conducted to ensure that the university's Export Control Compliance Program is operating effectively, including:
      1. Best practices:
         1. Faculty awareness education program.
         2. Export Control Determinations - The goal is to ensure that the guidelines of the Export Control Management System are being followed, that the processes are changed as needed and new processes are added when required.
   3. Compliance Assessment - A review of select contracts, activities, practices and procedures will be conducted to assess whether the University is successfully implementing the policies and procedures of the compliance program.
   4. Frequency of Internal Assessment - Policies and procedures assessments and compliance assessments will be conducted on an annual basis, and will consist of scheduled review

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1. Export-related Restricted, Denied and Blocked Persons Lists (BIS)
1. Department of Commerce Bureau of Industry and Security (BIS) Denied Persons List (www.bis.doc.gov)
2. Department of Commerce BIS Entity List (www.bis.doc.gov/entities/default.htm. ) (BIS)
3. Department of Commerce BIS Unverified List (www.bis.doc.gov/enforcement/unverifiedlist/unverified_parties.htm.) (BIS)
4. Department of State Arms Export Control Act Debarred Parties (www.pmddtc.state.gov/compliance/debar_intro.html. ) (DDTC)
5. Department of State Nonproliferation Orders: Missile Sanctions, Lethal Military Equipment Sanctions, Chemical and Biological Weapons Sanctions, Nuclear Sanctions ((www.state.gov/t/isn/c15231.htm. )
   This includes:
1. Executive Order 1338
2. Iran and Syria Nonproliferation Ac
3. Executive Order 12938 as amended
4. Missile Sanction law
5. Chemical and Biological Weapons Sanction Laws
6. Iran, North Korea and Syria Nonproliferation Act Sanctions (INKSNA)
6. Department of State International Traffic In Arms Regulations (ITAR) Munitions Export Orders (www.pmddtc.state.gov/regulations_laws/itar.html. ) (DDTC)
7. Weapons of Mass Destruction Trade Control Designations [OFAC] http://www.treasury.gov/resource-center/sanctions/Programs/Documents/wmd.txt. •
8. Department of State Terrorist Exclusion List http://www.state.gov/j/ct/rls/other/des/123086.htm.
9. U.S. Treasury Department Palestinian Legislative Council List [OFAC] http://www.treasury.gov/resource-center/sanctions/Terrorism-Proliferation-Narcotics/Pages/index.aspx
10. U.S. Federal Register General Order www.archives.gov/federal-register/index.html
2. Sanction Programs Related Blocked Persons Lists
1. Department of Treasury Specially Designated Nationals and Blocked Persons, including Cuba and Merchant Vessels, Iran, Iraq and Merchant Vessels, Sudan Blocked Vessels http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx. (OFAC)
1. Department of Treasury Specially Designated Terrorist Organizations and Individuals http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx.
2. Department of Treasury Specially Designated Narcotic Traffickers and Narcotics Kingpins http://www.treasury.gov/resource-center/sanctions/Programs/Documents/narco_designations_kingpin.pdf.
3. Department of Treasury Foreign Narcotics Kingpins www.treasury.gov/resource-center/sanctions/Programs/Documents/.
4. List of Foreign Financial Institutions Subject to Part 561 http://www.iranwatch.org/sites/default/files/us-treasury-561list-073112.pdf.
5. U.S. Treasury Department Foreign Sanctions Evaders List (FSE-IR, FSE-SY) http://www.treasury.gov/ofac/downloads/fse/fselist.pdf. (OFAC)
6. United Nations Consolidated List http://www.un.org/sc/committees/list_compend.shtml.
1. U.N. sanctions measures (assets freeze, travel ban, or arms embargo) imposed by the Security Council on Individuals and entities under Security Coumcil Resolutions 751 (1992) and 1907 (2009) concerning Somalia and Eritrea, 1267 (1999) and 1989 (2011) concerning Al-Qaida and associated individuals and entities, 1518 (2003), 1521 (2003) concerning Liberia, 1533 (2004) concerning The Democratic Republic of the Congo, 1572 (2004) concerning Cote d'Ivorie, 1591 (2005) concerning The Sudan, 1918 (2006), 1970 (2011) concerning Lybia, 1988 (2011), and 2048 (2012) concerning Guinea-Bissau.
7. U.S. General Services Administration (GSA) List of Parties Excluded from Federal Procurement Programs (www.gsa.gov and www.epa.gov/ogd/sdd/espl.htm.) (SAM/EPLS)
8. U.S. General Services Administration (GSA) List of Parties Excluded from Federal Non-procurement Programs (www.gsa.gov and www.epa.gov/ogd/sdd/espl.htm.) (SAM/EPLS)
9. U.S. General Services Administration (GSA) List of Parties Excluded from Federal Reciprocal Programs (www.gsa.gov and www.epa.gov/ogd/sdd/espl.htm. ) (SAM/EPLS)
3. Law Enforcement –related Wanted Persons List (Domestic)
1. U.S. Air Force Office of Special Investigations – Top Ten Fugitives http://www.osi.andrews.af.mil/library/fugitives/index.asp.
1. Focuses on four priorities: to exploit counterintelligence activities for force protection, to resolve violent crime impacting the Air Force, to combat threats to Air Force information systems and technologies, and to defeat and deter acquisition fraud.
2. Bureau of Alcohol, Tobacco, Firearms, and Explosives Most Wanted http://www.atf.gov/content/ATF-most-wanted.
1. Enforces U.S. federal laws and regulations relating to alcohol, tobacco products, firearms, explosives, and arson.
3. FBI Ten Most Wanted Fugitives
1. Investigative functions fall into the categories of applicant matters, civil rights, counterterrorism, foreign counterintelligence, organized crime/drugs, violent crimes and major offenders, and financial crime.
4. FBI Most Wanted Terrorists http://www.fbi.gov/wanted/topten/.
1. Lists alleged terrorists that have been indicted by sitting Federal Grand Juries in various jurisdictions in the United States for the crimes reflected on their wanted posters.
5. Federal Bureau of Investigation (FBI) Wanted Fugitives http://www.fbi.gov/wanted/wanted_by_the_fbi.
6. FBI Crime Alert http://www.fbi.gov/wanted/alert/.
7. FBI Seeking Information http://www.fbi.gov/wanted/seeking-info/.
8. FBI Hijack Suspects http://www.fbi.gov/wanted/wanted_by_the_fbi.
9. Food and Drug Administration – Clinical Investigators http://www.accessdata.fda.gov/scripts/cder/cliil/index.cfm.
10. Food and Drug Administration – Disqualified and Restricted.
    http://www.accessdata.fda.gov/scripts/SDA/sdNavigation.cfm?sd=clinicalinvestigatorsdisqualificationproceedings&previewMode=true&displayAll=true.
11. Food and Drug Administration – Debarment List http://www.fda.gov/ICECI/EnforcementActions/FDADebarmentList/default.htm.
1. Individuals that have had various restrictions placed against them by the Food and Drug Administration (FDA) for scientific misconduct.
12. Department of Homeland Security Most Wanted Fugitive Criminal Aliens http://www.ice.gov/most-wanted/hsi.htm.
1. Terrorism, Drug Smuggling, Money Laundering, Human Trafficking/Smuggling, Import/Export Violations, Child Pornography/Exploitation, Document and Benefit Fraud, Gang-related Crimes, Intellectual Property Rights Violations, Worksite Enforcement.
13. Naval Criminal Investigation Service – Wanted Fugitives http://www.ncis.navy.mil/ContactUs/Pages/WantedFugitives.aspx.
1. Conducts felony criminal investigations and counterintelligence for the Department of the Navy, and managing Navy security programs.
14. U.S. Immigration and Customs Enforcement Most Wanted http://www.ice.gov/.
1. ICE ERO prioritizes the apprehension, arrest and removal of convicted criminals, those who pose a threat to national security, fugitives, and recent border entrants.
15. U.S. Drug Enforcement Administration – Major International Fugitives http://www.justice.gov/dea/fugitives.shtml.
1. Enforces controlled substances laws and regulations of the United States and brings to the criminal and civil justice system of the United States those entities and individuals involved in the growing, manufacture, or distribution of controlled substances appearing in or destined for illicit traffic in the United States.
16. U.S. Marshals Service – Top 15 Most Wanted http://www.usmarshals.gov/investigations/most_wanted/index.html.
17. U.S. Marshals Service – Major Fugitive Cases http://www.usmarshals.gov/investigations/major_cases/index.html.
1. Involved in most every federal law enforcement initiative. U.S. Marshals major cases and top 15 most wanted consist of individuals with a history of violent crimes that may be considered armed and dangerous.
18. Office of Research Integrity PHS Administrative Actions http://ori.hhs.gov/administrative-actions.
1. The names of individuals that have had administrative actions imposed against them by the Office of Research Integrity (ORI), maintained by the Public Health Service (PHS). The Assistant Secretary for Health (ASH) makes the final PHS decision on findings of research misconduct and the imposition of administration actions after reviewing the recommendations made by ORI.
19. U.S. Postal Inspection Service – Most Wanted https://postalinspectors.uspis.gov/pressroom/wanted.aspx.
1. Important areas of jurisdictions include: assaults, bombs, controlled substances, electronic crimes, mail fraud, and money laundering.
20. U.S. Secret Service – Most Wanted http://www.secretservice.gov/mostwanted.shtml.
1. The United States Secret Service is mandated to carry out two missions: protection and criminal investigations. In criminal investigation, the Secret Service is responsible for the enforcement of laws relating to counterfeiting of obligations and securities of the United States, investigation of financial crimes including, but not limited to access device fraud, financial institution fraud, identity theft, computer fraud, telecommunications fraud, and computer based attacks on our nation's financial, banking, and telecommunications infrastructure.
21. U.S. Office of the Inspector General List of Individuals/Entities Excluded from Federal Health and Medicare Programs
22. Department of State Arms Control Act Debarred parties http://pmddtc.state.gov/compliance/debar.html. (DDTC).
23. Department of State Designated terrorist Organizations http://www.state.gov/j/ct/rls/other/des/123085.htm.
24. Department of State Terrorist Exclusion list http://www.state.gov/j/ct/rls/other/des/123086.htm.
25. U.S. Treasury Department Palestinian Legislative Council List http://www.treasury.gov/resource-center/sanctions/Terrorism-Proliferation-Narcotics/Documents/plc_list.txt. (OFAC)
26. Specially Designated Nationals and Blocked Persons (OFAC).
27. Department of Homeland Security Most Wanted Most Wanted Human Smugglers http://www.ice.gov/most-wanted/hsi.htm.
28. U.S. Central Command Iraqi SS Most Wanted http://www.fact-index.com/u/u_/u_s__list_of_most_wanted_iraqis.html#.
4. Politically Exposed persons and Office of Inspector general
1. Politically Exposed Persons and Office of Inspector General http://oig.hhs.gov/.
1. Chiefs of State and Cabinet Members of Foreign Governments [Central Intelligence Agency]
2. Office of Inspector General List of Individuals/Entities Excluded from Federal Health and Medicare Programs
5. International Terrorist, Blocked Person, Wanted, and Entity Lists
1. European Union Consolidated List http://eeas.europa.eu/cfsp/sanctions/consol-list_en.htm.
2. Japan Foreign End-Users of Concern
3. Canada Public Safety and Emergency Preparedness Listed Entities http://www.publicsafety.gc.ca/index-eng.aspx.
4. Politically Exposed Persons in Money Laundering Risk Countries (CIA)
5. Australia Department of Foreign Affairs and Trade Consolidated List http://www.dfat.gov.au/sanctions/consolidated-list.html.
6. European Union (EU) Council Regulation on Restrictive Measures to Combat Terrorism [Designated Persons, Groups, and Entities http://www.consilium.europa.eu/uedocs/cmsUpload/080206_combatterrorism_EN.pdf.
7. Interpol Recently Wanted http://www.interpol.int/notice/search/wanted.
1. Lists person that are wanted by national jurisdictions
8. Bank of England Consolidated List of Financial Sanctions Targets in the U.K https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/292041/terrorism.pdf.
9. World Bank Listing of Ineligible Firms http://web.worldbank.org/external/default/main?theSitePK=84266&contentMDK=64069844&menuPK=116730&pagePK=64148989&piPK=64148984.
1. Lists names of firms and individuals that are ineligible to be awarded a World Bank-financed contract for the periods indicated because they were found to have violated the fraud and corruption provisions of the Procurement Guidelines or the Consultants Guidelines.
10. OSFI Consolidated List – Entities http://www.osfi-bsif.gc.ca/Eng/fi-if/amlc-clrpc/atf-fat/Pages/default.aspx.
11. OSFI Consolidated List – Individuals
    1. Office of the Superintendent of Financial Institutions (OSFI) issues names subject to the regulations establishing a list of entities made under the Canada Criminal Code or the United Nations suppression of terrorism regulations. OSFI is the sole regulator of banks, and the primary regulator of insurance companies, trust companies, loan companies and pension plans in Canada.
12. OSFI Warning List
    1. Issues entity names that may be of concern to the business community and the public.
13. OCC List of Unauthorized Banks http://www.occ.gov/news-issuances/alerts/2010/alert-2010-12.html.
14. Royal Canadian Mounted Police (RCMP)-Wanted Fugitives http://www.rcmp-grc.gc.ca/eng/wanted-by-the-rcmp.
1. Kingdom of Saudi Arabia Wanted Militants
2. HM Treasury Consolidated List https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets.
3. Canadian Border Services Agency Most Wanted List http://www.cbsa.gc.ca/wc-cg/menu-eng.html.
4. Violations of human or international rights under the Crimes Against Humanity and War Crimes Act or under international law.
6. Export Risk Country Alerts
1. Department of Commerce, EAR Part 736 General Prohibition Three (Foreign-produced direct product re-exports)
2. Department of Commerce, EAR Part 736 General Prohibition Eight (In transit shipments and items to be unladen from vessels or aircraft)
3. Department of Commerce, EAR Part 740, Country Group E:1, Terrorist Supporting Countries
4. Department of Commerce, EAR Part 744, Subject to military end-user and end-use based control policy for specified ECCN dual-use items
5. Department of Commerce, EAR Part 746, Embargoes and Other Special Controls (embargoes, sanctions, or special controls on specified items)
6. Department of State U.S. Arms Embargoes
7. Department of State, Restricted export destinations under the ITAR (126.1) including denial policy
8. Department of State, DDTC policy restrictions, limitations, or delays on license applications for the export of USML items
9. Department of State, State Sponsors of Terrorism
10. Department of State, Countries Not Cooperating Fully with United States Antiterrorism Efforts
11. Department of Treasury Office of Foreign Assets Control (OFAC) Sanctions or Specially Designated Nationals under OFAC Sanctions
12. United Nations (UN) Sanctions or Arms Embargoes
13. BIS India and Pakistan Export Restrictions, including Atomic Energy blocked entities and nuclear activities
14. Exports and reexports under restriction to Afghanistan
15. Countries that may require participation in, or cooperation with, an international boycott [Section 999(b)(3) of the Internal Revenue Code of 1986]
16. Government of Canada Economic Sanctions
17. U.S. Department of Commerce EAR Country Group E:1, Terrorist Supporting Countries
18. ("T-7 Countries")
19. Office of Foreign Assets Control (OFAC) Sanctions
20. United Nations (UN) Sanctions
21. U.S. Department of State, List of State Sponsors of Terrorism
22. Export destination for defense articles and defense services prohibited under the ITAR
23. (126.1)
24. BIS India and Pakistan
25. Exports and Reexports to Afghanistan Restrictions
26. Countries that may require participation in, or cooperation with, an international boycott
    [Section 999(b)(3) of the Internal Revenue Code of 1986] 

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• FBI Export control enforcement site at: http://export.gov/ecr/eg_main_027618.asp.
• The U.S. Department of Commerce's Bureau of Industry and Security (BIS) provide seminars on export controls related to commodities covered by the EAR. For a schedule of export control seminars available through BIS, please visit: http://www.bis.doc.gov/SeminarsAndTraining/elsem.htm. 
• BIS also offers a series of online training seminars that may be accessed at: http://www.bis.doc.gov/seminarsandtraining/seminar-training.htmhtml. 

ATTACHMENT 6
FACULTY/STAFF AWARENESS WORKSHOPS 

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1. Workshop Format:
1. Export Control Basics
1. Purpose of U.S. export control laws
2. Regulatory agencies controlling exports
3. The effect of U.S. export controls on universities
4. Fundamental research/education/employment exclusions
5. Examples of the exclusions
6. Enforcement: violations and penalties
7. Discussion/Question
2. What Faculty Need to Know
   1. Deemed Export
   2. What is a deemed export and how does it occur
   3. Handout and case studies
   4. Foreign National
   5. Definition of foreign national
   6. Transfer of controlled technology to foreign national
   7. International travel
   8. Case studies/discussion/questions
3. Key Issues for the University: Determining Whether or Not the Export Control Laws Apply to Research
1. Visas-Country of Origin
2. Identifying and securing all controlled equipment
3. Chart/ case studies/ Gray areas of research/Best practices
4. University departments that warrant export attention
5. The responsibility of the P.I.
4. The Far Reaching Impact of Export Controls on Universities
1. Current Issues
2. Proposed changes in "use" technology
3. Proposed DoD changes, badging of foreign nationals
5. Discussion/Questions/Close.

ATTACHMENT 7
FREQUENTLY ASKED QUESTIONS

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