UVA Export Controls Policy

 

Current versions of all approved policies are available through the University of Virginia Policy Directory. Policy FIN-043 Managing Exports of Controlled Technology to Foreign Persons and Destinations in Support of Research and Scholarship is the formal expression of the University's commitment to export control compliance. Two oversight executives are identified, the Vice President/Chief Financial Officer and the Vice President for Research. The policy identifies the specific responsibilities of University members and specifies that procedures associated with this policy may be found on the Office of Export Controls website (these pages). The following are excerpts from the version approved on 3/13/2012.

Reason for Policy

Academic inquiry may require the use of certain technology that is controlled by or produces results that are subject to federal export control regulations. In such cases, the University is fully committed to complying with all applicable export controls that pertain to the conduct and dissemination of our research. Serious penalties, both civil and criminal, can result from U.S. export control violations. The University is required to demonstrate due diligence with respect to export control compliance and to document its adherence to U.S. export controls and trade sanctions laws.

This policy describes the general guidelines for compliance with U.S. export control regulations and, when such regulations apply, the impact for researchers on the conduct of their research and dissemination of data, results, products and deliverables.

Policy Statement

The University discourages any restriction on the ability of its students, faculty and staff to communicate unclassified information to any individuals, including foreign nationals and institutions, engaged in research at the University or in the international community of scholars. However, faculty are not prohibited from accepting restrictions; those wishing to engage in controlled activities must assist the University in preventing unauthorized disclosures and exports. Because export controls place restrictions on the dissemination of information and on access by foreign nationals in the U.S. as well as transfers abroad, the University has determined that projects proposing to use or produce controlled technology require special review and authorization to ensure that they will not interfere with the University’s mission.

The Director of the Office of Export Controls shall be the University’s principal point of contact for agencies with regulatory or enforcement authority under the export control regulations.