Forms, Policies & Procedures

Export Compliance Program Manual

The U.S. export control system generally requires export licensing for defense items, for items that have both commercial and military applications, and for exports to sanctioned persons and destinations. U.S. national security, economic interests and foreign policy shape the U.S. export control regime. The export laws and regulations aim at achieving various objectives, such as preventing the proliferation of weapons of mass destruction, advancing the U.S. economic interests at home and abroad, aiding regional stability, implementing anti-terrorism and crime controls, and protecting human rights.

These controls generally restrict the export of products and services based on the type of product and the destination of the export. In both the defense and high-technology sectors, the U.S. Government tightly regulates the export not only of equipment and components, but also of technology. Technology includes technical data, such as blueprints and manuals, as well as design services (including the transfer of “knowledge”) and training. U.S. laws assert jurisdiction over U.S.-origin equipment and technology even after it is exported (i.e., restricting the re-export or re- transfer to third parties). In addition to general export licensing, the United States maintains economic embargoes against a number of countries whose governments consistently violate human rights or act in support of global terrorism. Such embargoes bar most transactions by U.S. persons with these countries. Finally, the U.S. Government maintains lists of Specially Designated Nationals or persons and entities that are barred from conducting export business because of previous activities.

Three principal agencies regulate exports from the United States: the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”) administers export control of defense exports; the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) administers export control of so-called “dual-use” technology exports; and the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) administers exports to embargoed countries and specially designated entities.

DEFINITIONS:

APRRA– Associate Provost for Research & Regulatory Affairs
BIS– Department of Commerce Bureau of Industry and Security
CCL– Commerce Control List
CJ– Commodity Jurisdiction
DDTC– Department of State Directorate of Defense Trade Controls
EAR– Export Administration Regulations
ECCN– Export Control Classification Number
EO– Empowered Official
DRRA – Director of Research Regulatory Affairs
ITAR– International Traffic in Arms Regulations
OFAC– Department of the Treasury Office of Foreign Assets Control
RO– Research Office
PI– Principal Investigator
SDN– List Specially Designated Nationals and Blocked Persons List
TCP– Technology Control Plan
USML– United States Munitions List
UD– University of Delaware