The researcher / project director has primary compliance responsibility regarding export control laws and regulations. The UNC Asheville Export Control Officer will assist the researcher / project director in fulfilling those responsibilities.
Prior to beginning any research project that may be subject to export control laws and regulations, the researcher / project director should notify, as early as possible, the Export Control Officer that the work planned may be subject to export controls under EAR, ITAR or OFAC. The Export Control Officer will review the proposal or statement of work and contract to determine if the technology involved is subject to export controls.
If the planned research is subject to export controls and is funded, before starting work on the research project, the investigator(s) will cooperate with the Office of Research and Sponsored Programs to manage the specific export control issues. Management mechanisms include, but are not limited to the following:
- A customized Technology Control Plan (TCP) that will outline the provisions for protecting the controlled technology and technical data such as physical/information security plans and end-of-project security measures.
- Export Control Training for all the personnel involved in the project.
- Personnel screening against Denied Persons Lists.
- Obtaining an export license from the appropriate federal agency, if required. Note: Licensing could take up to a year to get approvals.
During the project, it is the responsibility of the researcher / project director to inform the Export Control Officer of any changes to the scope of the project and additions to project personnel for reevaluation of the export control mechanisms in place. The TCP will also need to be updated accordingly.
The researcher / project director and the project personnel will ensure that the access of foreign nationals to the restricted data or technology is denied unless an export license has been obtained.
It is the researchers / project directors responsibility to report to the Export Control Officer any violations of export control laws and regulations related to his/her export controlled project.
At the completion of the project and/or when leaving/terminating university employment, the researcher / project director will ensure that the restricted technology is securely removed/stored and the restricted technical data is disposed of according to the end-of-project security measures outlined in the TCP.