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Export Control Key Roles
Export Control Key Roles and Responsibilities
Export control requires full institutional commitment to ensure success. Senior university officials have a responsibility to ensure that adequate resources and managerial support exist to enable the institution to fully comply with export control rules and regulations, as well as resolution of any issues.
The sections below outline key roles and responsibilities related to export controls.
Export Control Key Roles and Responsibilities
<p>The Empowered Official(s) have the authority to represent the institution in matters related to registration, licensing, commodity jurisdiction and classification requests, and voluntary or directed disclosures. Only Empowered Officials may sign paperwork and bind the institution in actions with government agencies related to export control responsibilities.</p>
<p>The ECO is responsible for leading and managing the export control program to ensure compliance with all applicable export control laws, regulations, and institutional policy. The ECO directs and delegates the day-to-day operational management of UCCS’s export control program. The ECO has the authority and the responsibility to implement the procedures set forth on the Export Control website and manual and should be consulted when questions related to export compliance or international shipping arise.</p>
<p>The Office of Sponsored Programs and Research Integrity (OSPRI) is the main institutional office of record with oversight of export control issues.</p>
<p>Principal Investigators have expert knowledge about certain types of information and technology used in a research project or other University activity, such as presenting at conferences, as well as through discussions with fellow faculty and collaborators. Faculty members share in the responsibility of export control compliance. Before engaging in any research project or activities that may be subject to export controls, faculty should consult with OSPRI.</p>
<p>Faculty, staff, and students are responsible for ensuring that their educational, research, and other business activities involving international collaborations and foreign exchanges are conducted properly and in compliance with U.S. export, sanctions, or security regulations and any procedures identified herein or in the Technology Control Plan. If faculty, staff, or students are involved in classified research, controlled unclassified research, international collaborations, or foreign exchanges with risk of export control, sanction, or security regulation violation, they will comply with the provisions of any license, government approval, policy, or technology control plan, or other procedure.</p>
<p>The ECO assists faculty, staff and students in assessing export control requirements on a case-by-case basis.</p>
<p>Academic deans, directors, and department chairs share the responsibility of overseeing export control compliance in their respective schools, departments, centers, or institutes. They support the ECO to identify international collaborations, travel, services, and online study requiring OFAC licenses. They also help the ECO implement procedures as deemed necessary for export control compliance. For example, college/school deans, department chairs, and others sign technology control plans (TCP) as needed.</p>
<p>In addition, the directors of other offices or units on campus including, but not limited to, Accounting, Environmental Health and Safety, Human Resources, International Affairs, Office of Information Technology, and the Office of the Registrar share the responsibility of overseeing export control compliance in their units and supporting the ECO in implementing procedures as deemed necessary by the ECO for export control compliance.</p>