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Export Control and Sanctions

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Export control and sanctions regulations were developed with the intention to allow as much international engagement as possible, while holding back on a few key types of interactions for the purposes of protecting U.S. national security, advancing U.S. economic interests, and achieving U.S. foreign policy objectives.

 

The UMKC export controls program is part of the broader UM System Research Security and Compliance Program. The University of Missouri System has implemented CRR 430.020 Export Control and Sanctions Compliance and has developed an Export Compliance Management Program. Additionally, UMKC has the following SOPs in place:

Export Controls and Sanctions SOP #001: Recordkeeping

Export Controls and Sanctions SOP #002: Sponsored Programs

Export Controls and Sanctions SOP #003: Technology Control Plans

Export Controls and Sanctions SOP #004: Certain Agreements and Intellectual Property Protections

Export Controls and Sanctions SOP #005: International Shipping of Biological Materials

Export Controls and Sanctions SOP #006: Training

Export Controls and Sanctions regulate how U.S. Persons and people located in the U.S. share items, information, and services with other countries. There are a variety of laws (e.g., the Arms Control Act of 1976 and the Export Control Reform Act of 2018) that have empowered various federal agencies to implement regulations controlling certain activities. Several of these sets of regulations are focused on the export of items, technology, and software that have either a purely military purpose or that have both a military and commercial application. Other regulations govern the sharing of nuclear items and technologies outside of the United States.

Any activity with a party subject to sanctions or located in a comprehensively sanctioned destination requires the review and approval of a university export compliance professional. Sanctioned destinations are: Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine.

Broadly speaking, export control regulations include, but are not limited to:

  • Foreign Assets Control Regulations (FACR) issued by the U.S. Department of the Treasury, Office of Foreign Assets Control
  • International Traffic in Arms Regulations (ITAR) issued by the U.S. Department of State, Directorate of Defense Trade Controls
  • Export Administration Regulations (EAR) issued by the U.S. Department of Commerce, Bureau of Industry and Security

While large portions of university activities are not subject to these regulations, it is important to ensure that when we are engaging with foreign parties, we are doing so in a way that is ethical and does not inadvertently violate these regulations. Civil and criminal penalties for violations can be levied against both the University as well as individuals. As such, it is important to engage an export compliance professional prior to engaging with parties outside the United States.

Export Control Rules of Thumb (PDF)

For questions about export controls and sanctions, please reach out to us at export.control@umkc.edu.

To report any concerns, please email us at export.control@umkc.edu. Additionally, the Integrity and Accountability Hotline is available for all University faculty and staff, and provides a secure and confidential method for reporting any type of unethical or inappropriate conduct. Visit the Integrity and Accountability Hotline webpage (exit UMKC site) or call (844) 469-6383.