Export controls are federal laws and regulations that govern shipments and other transfers of commodities, technologies, services, and money to foreign countries. Export controls also regulate disclosures of sensitive information, including some research data, to non-U.S. persons. The regulations consider all of these transactions to be exports, even if all parties involved are in the United States.
In some cases, UNMC may need to obtain authorization from a federal agency, usually in the form of an export license, before personnel can participate in certain export transactions. The Export Control Office provides resources and other support to UNMC personnel engaging in export-controlled activities.
Although many UNMC activities are not subject to export licensing requirements, all personnel must be familiar with the regulations to ensure appropriate guidance is sought and action taken should they apply.
Export controls may apply to:
- International travel (especially travel to an embargoed country)
- Hosting visiting scholars and graduate students
- Research activities
Please contact the export control team if you are planning to engage in any of these activities, to schedule training, or have other questions about export controls.
In order to promote compliance with federal export laws and regulations, UNMC provides a training program for personnel who do or may engage in activities subject to export controls. All personnel involved in or supporting export-controlled activities must comply with all applicable U.S. laws and regulations while teaching, conducting research, or participating in other activities at or on behalf of the university.
Such personnel must complete training through the Collaborative Institutional Training Initiative Program (CITI), an online training platform. The Export Control Office (ECO) requires a passing score of 80% for each assigned module to validate training through CITI. Once completed, CITI training is valid for three years. Click here for information on registering for CITI.
The ECO may also require in-person training for activities subject to elevated security requirements, such as research projects covered by technology control plans (TCPs) or travel to embargoed or high-risk destinations. In-person training is tailored to the personnel and the specific controlled activity they are engaging in.
The ECO may also prescribe additional training or awareness measures not explicitly described in this policy. This may include completion of additional CITI modules, briefings by federal law enforcement or counterintelligence authorities, or other measures the ECO deems appropriate in light of the nature and sensitivity of the activities UNMC personnel propose to engage in.
These standards apply to all UNMC personnel engaged in or proposing to engage in activities subject to export controls. Activities subject to export controls include without limitation:
- Research subject to restrictions on the dissemination of results;
- Research subject to restrictions on participation by foreign persons;
- Research involving the use of items subject to export controls;
- Travel to embargoed or sanctioned countries for the purpose of conducting, presenting, or otherwise supporting research or other activities on behalf of UNMC;
- Establishing institutional relationships with restricted entities or entities in embargoed or sanctioned countries; and
- Exporting controlled items, including shipping, traveling internationally with items subject to export controls, and deemed exports.
Personnel requiring training are divided into cohorts depending on the nature of the activities they engage in and their role in those activities. Generally, most training requirements can be satisfied by completing the prescribed CITI module(s). In some cases, the ECO may require the completion of additional CITI modules and/or in-person training, depending on the nature and sensitivity of the activity.
All cohorts must complete at least an introduction to export compliance and an overview of federal sanctions programs.
Cohort 1: Academic and research personnel
This cohort includes principal investigators, co-investigators, visiting scholars, postdoctoral researchers, students, volunteers, technicians, support staff, senior leadership, and anyone else engaging in the activities described in this section, irrespective of whether they are compensated for doing so.
Academic research personnel include:
- Personnel directly involved in the design, conduct, or reporting of export-controlled research;
- Personnel who may need access to controlled items (including hardware, software, materials, or data) in order to conduct or support research;
- Support staff within academic and research units who are not directly engaged in gathering or analyzing research data but perform other functions in support of research activities (like purchasing goods or services, scheduling travel, assisting with funding proposal submissions, coordinating access to UNMC resources, etc.); and
- Deans, chiefs, and associate deans for research in colleges or departments where export-controlled activities are taking place.
Cohort 2: Administrative personnel
This cohort includes personnel in administrative units whose functions support export-controlled activities directly or indirectly.
Such administrative units include:
- Sponsored Programs Administration
- Human Resources
- Environmental Health and Safety
- General Supply and Mail Services
- Information Technology Security
- International Health and Medical Education
Cohort 3: Other personnel
This cohort includes faculty, staff, students, and other personnel who travel internationally (especially to embargoed countries) or provide support for export-controlled activities that does not place them in another cohort.
Cohort 4: The Export Control Office
The personnel of the ECO are committed to providing the highest level of service, and therefore are responsible for staying up to date on regulatory and policy changes.
|CITI Module||Cohort 1: Research & Academic Personnel||Cohort 2: Administrative Personnel||Cohort 3: Other Personnel||Cohort 4: Export Control Office|
|Introduction to Export Compliance||R||R||R||R|
|Export Compliance for Researchers (Part I)||R||S||E||R|
|Export Compliance for Researchers (Part II)||R||S||E||R|
|Export Compliance for Research Administrators||E||E||E||R|
|Export Compliance when Using Technology in Research||E||S||E||R|
|Export Compliance and Biosafety||E||E||E||R|
|Export Compliance for Operational Departments||S||R||E||R|
|Export Compliance for International Shipping||E||E||E||R|
|Export Compliance and Purchasing||S||E||E||R|
|Export Compliance and International and Foreign Waters||S||E||E||R|
|Export Compliance and Collaborations||E||E||E||R|
|Compliance Compliance and Distance Education||S||E||E||R|
|Export Compliance and United States Sanctions Programs||R||R||R||R|