Export Compliance – Why?
By Jennifer Horn
So, what is behind all these "export compliance" rules and regulations?
International trade matters drive some of the rules and regulations. For example, let's look at China. Our government is concerned about technology transfer and sensitive information getting into the "wrong" hands. The government wants businesses and universities to understand that production and development data related to sensitive materials cannot go to China without prior approval. The government is also concerned that technology could go through China and be diverted to another sanctioned country such as Iran.
In other areas of the world, such as Latin America, the U.S. government has more specific targets connected to money laundering or corruption. For those situations, our government maintains "lists" of sanctioned individuals and businesses. In some countries, universities have close ties to foreign military forces and are restricted for that reason.
So, if you are told that your research has "export controls" issues,
- it may be because of the subject matter of your research (sensitive information),
- it may be because you want to work with a researcher or institution in a country that our government has sanctioned for some diplomatic reason (human trafficking, money laundering, supporting terrorism),
- it may be that the individual or institution has committed acts that have placed them on a list of parties we are not permitted to do business with, or
- it could be a multitude of other reasons.
The reasons vary widely. If you are notified that a project or person has been "flagged"
for potential export issues, it does not mean you will not be able to proceed. It
does mean that you will need to work with the Director of Export and Security Compliance
(me) to resolve the issue before beginning your project. I look forward to working
with you to move research forward at TTU in a way that protects you and the university
from violations of federal law.
Jennifer Horn is Director of Export and Security Compliance in the Office of the Vice President for Research