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firstname.lastname@example.org. Please note that university personnel who chose to export items without consulting ORIA may be held personally liable for violating the export compliance regulations. We encourage you to speak with us concerning your project well in advance of making shipments overseas. ORIA can help you with:
- Making sure you understand which regulations apply to your shipment
- Preparing export license applications or documenting the use of an export license exceptions
- Electronic Export Information (EEI) preparation and submission of other electronic or paper forms to make sure your shipment is properly documented
- Performing restricted party screening
- Advising on appropriate retention times for your export records
- Assisting you in responding to government requests for export documentation
- Contacting a customs broker who can work with Mason personnel, if advisable
- Other export-related matters that may be unique to your project
Mason’s Office of International Programs and Services (OIPS) works with Mason Schools that wish to invite foreign scholars to visit Mason. Please visit the OIPS site (linked in the university resources section) for information and forms for both J-1 Visitors and for permanent faculty appointments. OIPS and ORIA work closely to ensure our visitors’ activities at Mason meet applicable export control and sanctions regulation requirements. As part of this process, Mason hosts may be asked to provide information concerning the visitor’s research program, the host’s sponsored research projects, and other relevant matters.
I. PurposeTo establish procedures for complying with applicable export laws and regulations, including the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and Foreign Assets Control Regulations (FACR), relating to sponsored projects.
II. General PolicyAll departments, faculty, and students must comply with export controls, sanctions/economic embargoes, and Mason policies and procedures governing the execution and performance of sponsored projects. The Office of Sponsored Programs (OSP) and the Office of Research Integrity & Assurance (ORIA) will coordinate activities with the departments and Principal Investigators (PI) to determine if a proposed sponsored project is subject to export and/or sanctions regulation; to ensure that security measures needed to prevent unlawful export of controlled items, (including software, technology, or technical data) to foreign nationals, are in place; and to ensure that sponsored project contracts are executed in compliance with applicable export control and trade sanctions laws. The Associate Vice President of Research Operations (AVP OSP) and the Director of Export Compliance and Secure Research (DEC) approved this procedure and are responsible for implementation.
III. DefinitionsTechnology Control Plan (TCP): A plan, prepared by the PI and approved by the department and ORIA, to prevent the unauthorized export of restricted commodities, defense articles or defense services, software, technology, or technical data and to ensure the proper safeguarding of controlled unclassified information (“Controlled Items”).
A. OSP will:
- Identify, and notify ORIA of sponsored projects that: Contain terms or conditions related to: • export control regulations, • foreign person restrictions (or prior approval of project participants on an individual basis by the funder), • publication restrictions or pre-publication review requirements, • security language such as “sensitive but unclassified,” • safeguarding of controlled unclassified information, controlled defense information, or similar conditions. Or involve: • U.S. government sponsors such as Department of Defense, a branch of the U.S. armed services, NASA, Department of Energy, National Security Agency, any intelligence agency, or similar U.S. or foreign government departments, • military applications, articles or defense services, • receipt of export-controlled information (as research “inputs”), • encryption, • bacteria, or viruses (or their toxins and genetic material), or radiation (or countermeasures to it), • plant or animal pathogens, • foreign collaborators where equipment exchanges are contemplated, • delivery of a prototype (including software) or chemical or biological sample or product, when the provided material or information will not be made freely available to the public, • international travel or work to be performed outside of the U.S., • parties within or collaboration with, or funding from a country subject to comprehensive U.S. economic sanctions, • receipt of a sponsor’s tangible equipment, • receipt of biological materials or select agents under a Material Transfer Agreement.
- Provide adequate documentation to ORIA to perform an export review, including copies of the award and the Statement of Work.
- If a TCP is required, ensure that the TCP is approved by ORIA prior to the release of funds.
- Assist the PI and ORIA in negotiating sponsored projects terms and conditions, including written confirmation of fundamental research.
- Verify that documents relating to sponsored projects with a TCP requirement are stored in a black folder, and that the folder contains a copy of the TCP and related certifications.
- Consult with the PI and/or ORIA when substantive changes are proposed to a sponsored project that has a TCP (e.g. personnel or equipment added, venue or scope of work changed).
- Provide a copy of each Material Transfer Agreement to ORIA and ensure that the provider has indicated the Export Control Classification Number for each item transferred.
- When directed by ORIA, AVP OSP will freeze any sponsored project funds identified as a source of a potential export or sanctions violation or noncompliance issue.
- Maintain records of sponsored projects with a TCP requirement for 5 years after the close of the project (or longer, at ORIA’s request).
B. ORIA will:
- Assist the PI and the OSP Contracts Team in determining if a sponsored project will be restricted under export control regulations.
- Assist the PI and the OSP Contracts Team in putting an interim technology control plan in place in situations where a PI has received an “Authorization to Proceed” letter from a sponsor.
- Assist the PI and OSP in negotiating sponsored projects terms and conditions, including written confirmation of fundamental research.
- Submit requests for export licenses, commodity jurisdiction, commodity classifications, and other documents required by applicable export control regulations that relate to sponsored projects.
- If required, advise the PI and OSP of the need for a TCP for any export controlled sponsored project and assist in the preparation and review of the TCP.
- Provide an executed copy of the TCP to OSP to keep in the contract file.
- Provide training on a regular basis for faculty and students to increase awareness of the basics of export control and sanctions regulations and promote compliance. Specialized training will be conducted for personnel working under a TCP, and, when considered necessary by ORIA or OSP to ensure compliance, training will be conducted for personnel supporting fundamental research sponsored projects.
- Notify AVP OSP in writing of any potential export or sanctions violation(s) or noncompliance issues affecting sponsored projects, and direct freezing affected sponsored project funds, if required.
- Maintain a record of all documentation required by export control regulations relating to sponsored projects.
C. Departments, PI and personnel supporting a sponsored project that may be, or that has been determined to be subject to export controls will:
- Assist OSP and ORIA in negotiating sponsored projects terms and conditions, including written confirmation of fundamental research.
- Assist in the preparation and execution of a project‐specific TCP for any sponsored project subject to export controls.
- Provide export control classification numbers and/or, assist ORIA in classifying (for export control purposes) the technology, software or items involved in the sponsored project.
- Comply with all security measures in the TCP, and, throughout the life of the project, take and document appropriate additional steps, if any, to prevent the unauthorized export of Controlled Items.
- Forward relevant export-related documentation to ORIA for recordkeeping.
- Attend export controls training. The PI will ensure that students or other researchers involved in the project attend such training, and will take additional measures, as appropriate, to ensure that all project personnel are appropriately briefed on and follow project-specific export controls/sanctions safeguards.
- Upon request, certify to ORIA their own and their research team’s compliance with the TCP.
- for each export‐controlled sponsored project for which they are responsible.
Federal Export and Sanctions Compliance Checklist
EquipmentNotify email@example.com prior to bringing to Mason any export controlled equipment that you and/or others will use in research or on projects. Military items are export controlled, as are dual-use items – items that have both a military and a civilian use – such as certain drones, lasers, and sensors. You must make this advance notification so that our export office can determine whether we need to assist you in putting special safeguarding provisions in place. If you are uncertain whether your equipment is subject to export controls, please contact firstname.lastname@example.org.
International Research CollaborationIf you wish to collaborate with researchers at a foreign institution, contact email@example.com. Our office will help you determine whether the collaboration is permissible under Federal law, or whether the collaboration requires a government license. If the research collaboration requires such a license, we will work with you to assemble the best possible case for licensure, and will make the license application on your behalf. We will also perform a “quick check” of the foreign colleagues (and their institutions) against publicly-available U.S. Government restricted party lists to determine whether the U.S. Government has imposed any restrictions on U.S. researchers’ ability to collaborate with those foreign parties.
TravelMost international travel at Mason does not present an export risk and does not require prior approval from our export office. However, you must contact firstname.lastname@example.org if any of the following apply:
- You have Mason-related travel to (or wish to present or attend a conference in) any of the following countries: Crimea region of Ukraine; Cuba; Iran; North Korea; Sudan; and Syria
- You are working on an export controlled project and need to travel internationally
- You need to ship or hand carry equipment, tools, technology, or software outside the United States, including a Mason laptop
TrainingMason is required by the U.S. Government to provide export and sanctions compliance training to all COS and VSE faculty members and researchers, including research assistants and appropriate staff. Faculty and researchers from other colleges are encouraged to take the training, which covers international travel and provides examples of how export and sanctions laws affect research and collaboration at Mason. This online training takes less than 30 minutes and can be accessed via My Mason using a browser other than Internet Explorer. To enroll in this online training, type “export” in the Organization Search box and follow these instructions:
- Under Organization ID, move your curser over “AU_Provost_ExportControl” and a down arrow will appear
- Click on Enroll, then Click Submit on this screen, then OK on the next screen