The University of North Carolina General Administration

Export Control ManagementExport Control ManagementPlan Development and ImplementationPlan Development and ImplementationPlan Development and ImplementationPlan Development and Implementation

July 24, 2007

The University of North Carolina General Administration

Areas of Exposure for UniversitiesAreas of Exposure for Universities

Unlawful or improperly documented exports

Deemed Exports Payments to denied persons or

entities

Unlawful or improperly documented exports

Deemed Exports Payments to denied persons or

entities

The University of North Carolina General Administration

Areas of Impact on CampusAreas of Impact on Campus

Personnel – faculty/staff recruitment Admissions – graduate and

undergraduate Research and technology transfer Accounting, procurement, materials

management, capital asset control Faculty International Travel Campus Visitors

Personnel – faculty/staff recruitment Admissions – graduate and

undergraduate Research and technology transfer Accounting, procurement, materials

management, capital asset control Faculty International Travel Campus Visitors

The University of North Carolina General Administration

Key Aspects of Campus Management Plans

Key Aspects of Campus Management Plans

Establish node of expertise and name an empowered official – demonstrable management commitment to compliance

Establish and distribute policies and procedures and adopt good documentation practices

Provide training for administrators, faculty and staff

Monitor for compliance and self-report non-compliance

Establish node of expertise and name an empowered official – demonstrable management commitment to compliance

Establish and distribute policies and procedures and adopt good documentation practices

Provide training for administrators, faculty and staff

Monitor for compliance and self-report non-compliance

The University of North Carolina General Administration

Assess the Campus Environment“Know the Rules”

Assess the Campus Environment“Know the Rules”

Federal Regulations• Be familiar with key concepts• Understand the subtle differences

between the various regulations• Understand the emerging profile of

export controls regulations and consequences for non-compliance

• Get buy-in endorsement from the top

Federal Regulations• Be familiar with key concepts• Understand the subtle differences

between the various regulations• Understand the emerging profile of

export controls regulations and consequences for non-compliance

• Get buy-in endorsement from the top

The University of North Carolina General Administration

Assess the Campus Environment“Know What You Have”

Assess the Campus Environment“Know What You Have”

Conduct an environmental scan• Identify laboratories or specialized

equipment that could be subject• Identify students and faculty from

restricted countries by program /department

• Identify key faculty, department heads and center directors

Conduct an environmental scan• Identify laboratories or specialized

equipment that could be subject• Identify students and faculty from

restricted countries by program /department

• Identify key faculty, department heads and center directors

The University of North Carolina General Administration

Assess the Campus Environment“Know Where People Go”

Assess the Campus Environment“Know Where People Go”

International Travel• Review and Approval• Understand restrictions for what can

be taken

International Visitors• Point of Invitation• Access to facilities

International Travel• Review and Approval• Understand restrictions for what can

be taken

International Visitors• Point of Invitation• Access to facilities

The University of North Carolina General Administration

Assess the Campus Environment“Know Who You Do Business With”

Assess the Campus Environment“Know Who You Do Business With”

Financial transactions• Procurement/Accounts payable • Honorarium payments

Materials Management• Shipment to restricted countries• Shipment of subject materials• Documentation

Financial transactions• Procurement/Accounts payable • Honorarium payments

Materials Management• Shipment to restricted countries• Shipment of subject materials• Documentation

The University of North Carolina General Administration

Start with Good DocumentationStart with Good Documentation

Policies and Procedures• Grounded in the federal regulations• Involve key stakeholders in development • Clearly articulate roles and responsibilities• Linked to corresponding policies in other

administrative units• Incorporate a communication plan• Broadly distributed

Policies and Procedures• Grounded in the federal regulations• Involve key stakeholders in development • Clearly articulate roles and responsibilities• Linked to corresponding policies in other

administrative units• Incorporate a communication plan• Broadly distributed

The University of North Carolina General Administration

Process and MonitoringProcess and Monitoring

Conduct Base-Line and Periodic Inventory• Restricted Persons (current and new)• Dual Use or Controlled Technologies• Documentation• Departing PIs and Post-Docs

International travel and visitors• Develop checklists

Conduct Base-Line and Periodic Inventory• Restricted Persons (current and new)• Dual Use or Controlled Technologies• Documentation• Departing PIs and Post-Docs

International travel and visitors• Develop checklists

The University of North Carolina General Administration

Training is KeyTraining is Key

Revamp compliance training New Faculty New Graduate Students Handbooks and administrative

policies and procedures

Revamp compliance training New Faculty New Graduate Students Handbooks and administrative

policies and procedures

The University of North Carolina General Administration

UNC Technical AssistanceUNC Technical Assistance

Campus briefings Group briefings Support for web-based information

resources

Campus briefings Group briefings Support for web-based information

resources

The University of North Carolina General Administration

Next StepsNext Steps

Secure management statement Engage various sectors in

development of procedures Train faculty and staff eCustoms training for academic,

research and business units

Secure management statement Engage various sectors in

development of procedures Train faculty and staff eCustoms training for academic,

research and business units