Dan Runge Export Compliance Officer (ECO) BSAG Meeting 6 December 2017

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Presentation transcript:

Dan Runge Export Compliance Officer (ECO) BSAG Meeting 6 December 2017 Export Controls and Sanctions Compliance: International Travel and Shipping Dan Runge Export Compliance Officer (ECO) BSAG Meeting 6 December 2017

UGA’s Office of Export Control Timeline Late 2012 to Early 2013 - Institutional Effectiveness Review of Office of Research April and May 2013 - Fischer and Associates Export Control Assessment and Recommendations Dec. 2013 – Fischer and Associates on campus July 2014 – Export Compliance Officer joins UGA, Office of Export Control is created

Office of Export Control Compliance Areas Economic and Trade Sanctions Prohibitions on transactions with restricted individuals, entities, countries, and economic sectors Export Controls U.S. laws and regulations that govern the transfer of controlled items or information to foreign nationals, entities, and countries for reasons of national security and foreign policy

Sanctioned and/or Embargoed Country Travel Iran U.S. Department of Treasury permission required May take 6+ months to receive Embargo limits what you can take with you Cuba 12 categories of Treasury Department authorized travel e.g., professional meetings, professional research, study abroad* ECO decides if travel meets is allowed New prohibitions on financial transactions with certain entities (hotels, Old Havana shops, etc…) Syria Crimea region of Ukraine and Sudan Sanctions limit activities and embargo limits exports North Korea Travel is prohibited

International Travel Approval AP Travel Authority (TA) and OIE Travel Registry (TR) TA required when travelling on behalf of UGA TR required for international travel approval ECO reviews TR the day after submitted Taking UGA-owned items, sanction and embargo compliance Risk Mitigation When traveling to sanctioned/embargoed destination, important to view TA and TR as more permissive than perfunctory Regardless of destination, submit TR as early as possible Provide as much detail as possible on TR, especially purpose of travel and institutions visiting

Export and Sanctions Issues in International Shipping No Centralized International Shipping What is being shipped and for what purpose? What is the destination country and who is the recipient? Best Practice Contact ECO well in advance of shipping Online request for international shipping review on Office of Export Control website

International Shipping Risk Mitigation Identifying export controlled items or information on campus Procurement, Sponsored Projects, Material Transfer and Non Disclosure Agreements ECO connects with Biosafety, ESD, Mail and Receiving Services Outreach to Departments ECO is assessing new international shipping review solutions University has a customs broker/freight forwarder/logistics firm that can assist

Dan Runge, J. D. , LL. M. Export Compliance Officer drunge@uga Dan Runge, J.D., LL.M. Export Compliance Officer drunge@uga.edu | 2-4188 Tucker 208 research.uga.edu/export-control