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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
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UGA’s Office of Export Control
Timeline Late 2012 to Early Institutional Effectiveness Review of Office of Research April and May Fischer and Associates Export Control Assessment and Recommendations Dec – Fischer and Associates on campus July 2014 – Export Compliance Officer joins UGA, Office of Export Control is created
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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
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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
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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
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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
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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
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Dan Runge, J. D. , LL. M. Export Compliance Officer drunge@uga
Dan Runge, J.D., LL.M. Export Compliance Officer | Tucker research.uga.edu/export-control
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