The University of North Carolina General Administration Export Control Management Plan Development and Implementation July 24, 2007

The University of North Carolina General Administration Areas of Exposure for Universities Unlawful or improperly documented exports Deemed Exports Payments to denied persons or entities Unlawful or improperly documented exports Deemed Exports Payments to denied persons or entities

The University of North Carolina General Administration Areas of Impact on Campus Personnel – faculty/staff recruitment Admissions – graduate and undergraduate Research and technology transfer Accounting, procurement, materials management, capital asset control Faculty International Travel Campus Visitors Personnel – faculty/staff recruitment Admissions – graduate and undergraduate Research and technology transfer Accounting, procurement, materials management, capital asset control Faculty International Travel Campus Visitors

The University of North Carolina General Administration Key Aspects of Campus Management Plans Establish node of expertise and name an empowered official – demonstrable management commitment to compliance Establish and distribute policies and procedures and adopt good documentation practices Provide training for administrators, faculty and staff Monitor for compliance and self-report non-compliance Establish node of expertise and name an empowered official – demonstrable management commitment to compliance Establish and distribute policies and procedures and adopt good documentation practices Provide training for administrators, faculty and staff Monitor for compliance and self-report non-compliance

The University of North Carolina General Administration Assess the Campus Environment “Know the Rules” Federal Regulations Be familiar with key concepts Understand the subtle differences between the various regulations Understand the emerging profile of export controls regulations and consequences for non-compliance Get buy-in endorsement from the top Federal Regulations Be familiar with key concepts Understand the subtle differences between the various regulations Understand the emerging profile of export controls regulations and consequences for non-compliance Get buy-in endorsement from the top

The University of North Carolina General Administration Assess the Campus Environment “Know What You Have” Conduct an environmental scan Identify laboratories or specialized equipment that could be subject Identify students and faculty from restricted countries by program /department Identify key faculty, department heads and center directors Conduct an environmental scan Identify laboratories or specialized equipment that could be subject Identify students and faculty from restricted countries by program /department Identify key faculty, department heads and center directors

The University of North Carolina General Administration Assess the Campus Environment “Know Where People Go” International Travel Review and Approval Understand restrictions for what can be taken International Visitors Point of Invitation Access to facilities International Travel Review and Approval Understand restrictions for what can be taken International Visitors Point of Invitation Access to facilities

The University of North Carolina General Administration Assess the Campus Environment “Know Who You Do Business With” Financial transactions Procurement/Accounts payable Honorarium payments Materials Management Shipment to restricted countries Shipment of subject materials Documentation Financial transactions Procurement/Accounts payable Honorarium payments Materials Management Shipment to restricted countries Shipment of subject materials Documentation

The University of North Carolina General Administration Start with Good Documentation Policies and Procedures Grounded in the federal regulations Involve key stakeholders in development Clearly articulate roles and responsibilities Linked to corresponding policies in other administrative units Incorporate a communication plan Broadly distributed Policies and Procedures Grounded in the federal regulations Involve key stakeholders in development Clearly articulate roles and responsibilities Linked to corresponding policies in other administrative units Incorporate a communication plan Broadly distributed

The University of North Carolina General Administration Process and Monitoring Conduct Base-Line and Periodic Inventory Restricted Persons (current and new) Dual Use or Controlled Technologies Documentation Departing PIs and Post-Docs International travel and visitors Develop checklists Conduct Base-Line and Periodic Inventory Restricted Persons (current and new) Dual Use or Controlled Technologies Documentation Departing PIs and Post-Docs International travel and visitors Develop checklists

The University of North Carolina General Administration Training is Key Revamp compliance training New Faculty New Graduate Students Handbooks and administrative policies and procedures Revamp compliance training New Faculty New Graduate Students Handbooks and administrative policies and procedures

The University of North Carolina General Administration UNC Technical Assistance Campus briefings Group briefings Support for web-based information resources Campus briefings Group briefings Support for web-based information resources

The University of North Carolina General Administration Next Steps Secure management statement Engage various sectors in development of procedures Train faculty and staff eCustoms training for academic, research and business units Secure management statement Engage various sectors in development of procedures Train faculty and staff eCustoms training for academic, research and business units