Research Compliance UNM MAIN CAMPUS OFFICE OF EXPORT CONTROL GUIDELINES FOR PURCHSING, INVENTORY CONTROL, AND SURPLUS PROPERTY RESEARCH ADMINISTRATORS.

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Presentation transcript:

Research Compliance UNM MAIN CAMPUS OFFICE OF EXPORT CONTROL GUIDELINES FOR PURCHSING, INVENTORY CONTROL, AND SURPLUS PROPERTY RESEARCH ADMINISTRATORS NETWORK MEETING APRIL 12, 2016

Research Compliance The Life Cycle of UNM Controlled Property

Research Compliance Program Structure - A Partnership The Office of Export Control Purchasing University Services Inventory Control Departments, Centers and Institutes Purchasing scientific or technical equipment is essential for the advancement of the University’s research mission. Together, we are supporting the University's research mission as well as mitigating risk to the institution and our investigators

Research Compliance Requisitioner Responsibilities It is the responsibility of the requisitioner or PCard holder to perform appropriate due diligence in order to determine if the item to be purchased is export controlled if the following conditions apply:

Research Compliance Requisitioner Responsibilities If the requisitioner determines that the item is export controlled they would select yes LoboMart and an export control review would be conducted.

Research Compliance Key Terms (this is not all inclusive) Areas of Concern: Electrical & Computer Engineering Chemical & Nuclear Engineering Manufacturing Engineering Engineering Centers Computer Science Physics & Astronomy Earth & Planetary Sciences Biology COSMIAC Terms to watch for: Lasers Sensors Robotics Optics High Level GPS systems Specialized cameras Non-commercial software ECCN- Export Control Classification Number EAR- Export Administration Regulations CCL- Commerce control list ITAR- International Traffic in Arms Regulations U.S. Munitions List

Research Compliance Purchasing Review of Terms and Conditions The Purchsing Officer will also conduct a review of the terms and conditions to identify language that may indicate that the item is controlled. If such language is found- an will be sent to the Export Control Officer and an export control review will be conducted.

Research Compliance Inventory Control Goal: Document and Manage If during the export control review it is determined that an item is controlled- the item will be flagged in the Banner system. A Technology Control Plan will be created to protect the item while it is in our custody. An annual audit will be conducted to ensure that the item is appropriately controlled. Notifications will be sent to the Office of Export Control if changes or the identified actions occur. (See flow chart in guidance document for more information)

Research Compliance Technology Control Plan The Technology Control Plan will include the following elements: 1. Who has access to the item(s) 2. Where on campus will the item(s) be located 3. Export control awareness training

Research Compliance University Services (Surplus Property) Goal: Appropriately Dispose If it is determined that the item is export controlled, special requirements for the buyer must be met: The special requirements may include: The buyer must be a U.S Person as defined in 22 CFR The buyer must show proof of citizenship in the form of a passport or birth certificate and government issued photo ID. The buyer must pass an Export Control Debarment Screening The buyer must have subject matter knowledge of the item to be purchased All special requirements must be met before the item will be released to the buyer. If the buyer does not meet with special requirements the item will become available to the next highest bidder.

Research Compliance Development and Training Phases Phase 1 Process Development Phase 2 Buisness Office Training Phase 3 Departmental Training

Research Compliance Q & A Thank you