Policies related to export control

Coordinator for this page

Franci Farnsworth, Middlebury

Best Practices

Best practices for an Export Management Control Plan indicate that the following elements should be included:

A) Policy Statement - informing external and internal audiences that the INSTITUTION'S system is committed to: 1) supporting compliance with all applicable export control regulations specifically; and 2) international security and WMD nonproliferation generally.

B) EMCP Organization - outline specific responsibilities within the EMCP. Specific Export Control Officers (ECO) would be identified to clearly describe: a) escalation path for decision-making and approvals; and b) management involvement and responsibility

C) Guidance and Procedures
  • Part IGuidance for INSTITUTION'S Faculty/Researchers (Primary Question Set)– a very simple Primary “question set” that might appear on: a) project approval forms; and b) an Export Compliance webpage, for internal use mainly (but probably ok for public consumption) – with link to screening tool.
  • Part IIApproval, Action and Escalation Procedures (Secondary Question Set) -- Secondary “question set” for ECOs who have received more specific training. This set (internal, not for public consumption) would help guide: a) determination that an export license requirement may exist; and b) an escalation/consultation process designed to confirm such a requirement. Note: This consultation could include seeking guidance from in-house/outside counsel. Example of ECU responsibilities at a typical CLASP institution:
  • Research Proposals (involving travel, equipment transfers, or workshop sponsorship) -- <ECO Managers: SRO or AOR>
  • I-129 Certification -- <ECO Manager: Staff responsible for helping students/faculty obtain visas>
  • Institutional Activities -- <ECO Manager: Staff at Centers or Institutes who have appropriate training; staff within academic or financial administration which could include SRO or AOR>

D) Training Procedures -- Procedures could be categorized into:
  • Basic awareness training to support Part I -- focused on general awareness that export regulations may govern research/project activity
  • Specific/advanced training to support Part II – this might include both internal training and attendance at outside export compliance seminars.

E) EMCP Audit and Revision (Updating) Procedures -- EMCP best practices include specific arrangements and procedures to audit the program – including ongoing review and revision.

F) Recordkeeping and Enforcement of Program
  • Document retention requirements
  • EMCP Best Practices include a mechanism for enforcement of the program – at a minimum a statement advising that “employees who disregard their responsibilities under this program may be subject to sanction, up to and potentially including dismissal”

Models & Examples

      • under construction ***

All CLASP policies collected on this topic

Hope College MI, Holland