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Research Policies

Section: Research
Policy Number: 6-17
Policy Name: Export Controls and Trade Sanctions
Date: August 5, 2008
Revisions:

1. PURPOSE

   To delineate the policy and guidelines governing the participation of faculty, staff and students in research falling under the Export Control and Trade Sanctions regulations.

2. POLICY

   The University of Delaware shall comply with Export Control and Trade Sanction (EC&TS) regulations governing applicable Sponsored Projects. The Provost serves as the final authority in any dispute resolution. The Associate Provost for Research has been designated as the Empowered Official. The Empowered Official will be responsible for EC&TS policies and procedures and will oversee the EC&TS compliance program including signing of Technology Control Plans (TCPs), license and disclosure requests, auditing of controlled Sponsored Projects and reporting of any EC&TS violations to the appropriate agencies. The Compliance Manager will work with the Empowered Official to develop appropriate procedures and will be responsible for implementing and maintaining EC&TS compliance procedures including TCP management, auditing and documentation.

   Implementation:
   

   1. The Principal Investigator (PI) has the primary responsibility for determining if the project is Export Controlled. The Empowered Official and the Compliance Manager will assist in this determination.

   2. The PI will work with the Empowered Official and the Compliance Manager to develop and implement appropriate TCPs for all projects falling under the EC&TS regulations. The TCP will be subject to audit by the Empowered Official and the Compliance Manager.

   3. The Compliance Manager is responsible for verifying the eligibility of all staff working on controlled projects. The PI is responsible for providing the Compliance Manager with the information required for this process and for making sure that all staff members with access to the controlled technologies and/or things have received adequate training on EC&TS.

   4. In the event that licenses are required, the PI will provide all required information for the licensing to the Empowered Official.

   5. The PI is responsible for the appropriate disposition of EC&TS controlled technologies in accordance with the technology control plan at the conclusion of the project and for reporting of this disposition to the Empowered Official.

      Link: Export Regulations

   Submitted by: Research Office