1. 政策声明

   It is the policy of newbb电子平台 that all employees, 学校, 部门, 中心, institutes and divisions must comply with U.S. government export control laws and regulations. No transactions are to be conducted by or on behalf of Ohio university contrary to U.S. export control laws and regulations.

2. 需求

   Ohio university employees with export responsibilities are required to have a working knowledge of export control laws and regulations, especially those governing their specific job functions, as well as a working knowledge of Ohio university procedures for export compliance.

   The primary regulations governing export controls are Export Administration Regulations (EAR) under the jurisdiction of the Department of Commerce, and International Traffic in Arms Regulations (ITAR), enforced by the Department of State. EAR and ITAR, however, are not the only regulations that impact export activity. Employees should review the university’s export compliance manual periodically as the myriad of laws and regulations affecting foreign transactions can be complex and penalties for violations can be severe.

   The scope of transactions that may be impacted by export control regulations is quite broad and includes more than the transport of tangible items or 技术 outside the United States.  Export control regulations can impact interpersonal relationships within the United States as domestic transfer of 技术 (EAR) or technical data (ITAR) to foreign nationals can be a “deemed export.”

   No transactions are to be initiated with individuals on the denied persons list, special designated nationals or terrorist list, or with any firms owned by or associated with those parties.  No exports are to be made to parties on the Entity List.

   Ohio university employees outside the U.S. cannot re-export any commodity, 技术, or software unless appropriate authorization has been obtained.  This includes foreign-produced items that are the direct product of U.S. 技术 and software or foreign-made items that are subject to national security controls of the U.S. as designated by the Commerce Control List (CCL).

   All Ohio university employees involved in or that are about to be involved in exports and re-exports, 交通, and related functions or activities are required to comply with the training requirements and procedures outlined in Ohio university's export compliance program and manual maintained by newbb电子平台’s export compliance committee.

3. Responsibility, sanctions and penalties

   All University employees are responsible for complying with U.S. export laws and regulations. Violations of export control laws and regulations can result in severe civil and/or criminal penalties to both the violating employee(s) and the University, as well as any significant administrative penalties.

4. Reporting inquiries

   Possible violations and questions should be addressed to:

   Ohio university export compliance committee at exportcompliance@俄亥俄州.edu. 

评论家

1. newbb电子平台 Compliance Committee
2. Office of Legal Affairs

形式, 参考文献, and 历史

1. 形式

   The following forms are specific to this policy:

   1. There are no forms associated with this policy. 

2. 参考文献

   The following items are relevant to this policy:

   1. Export Compliance Manual
   2. Export Compliance Webpage
   3. Export Administration Regulations
   4. International Traffic in Arms Regulations  

3. 历史

   Draft versions of this policy that were circulated for review, 他们的封面备忘录, 他们的形式, and 评论家' comments on them are available on the password-protected Review site.

   Prior versions of this policy were approved on:

   1. 2024年4月19日 (ESPC approved for interim use in accordance with policy 01.001)