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Export Controls

CSUSM is committed to complying with U. S. Export Control laws and regulations that apply to its activities, including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and the Office of Foreign Assets Control (OFAC) regulations. All individuals working at CSUSM who work with, or have access to, export-controlled technical data, information, materials, and equipment should be familiar with and fulfill the requirements of the U.S. export controls laws and regulations. This will include when traveling outside the United States.

In order to ensure compliance with export controls, it is critically important for university personnel to identify when their activities may trigger export controls. Typical university transactions or activities can or may have export control implications, including:

  • Collaborating with a foreign institution, person, military or entity
  • Receiving export controlled data, materials or research samples
  • Sponsored research awards which include publication restrictions, proprietary or export controlled information, technology, hardware or software, or request that only U.S. persons work on a project or the citizenship status of the research team
  • Foreign nationals’ access to controlled items or information
  • Shipping or hand-carrying equipment, items, samples or controlled data internationally
  • Developing a technology that may fall on the U.S. munitions list
  • Purchasing or receiving hardware or paperwork that the vendor or sponsor has designated “ITAR’, “U.S. Only”, “No Export”
  • Transactions involving sanctioned countries such as Cuba, Iran, North Korea and Syria
  • Consequences of Non-Compliance

    CSUSM faculty and staff must take steps to assure that they do not violate the export regulations and become personally liable for substantial civil and criminal penalties. The consequences of violating the OFAC, EAR, or ITAR regulations can be severe and can result in administrative, civil, or criminal penalties for the individual and for the institution.

    State Department (ITAR)

    • Criminal: up to $1,000,000 per violation, up to 10 years imprisonment
    • Civil: seizure & forfeiture of the articles and any vessel, aircraft or vehicle involved in attempted violation, revocation of exporting privileges, fines of up to $500,000 per violation.

    Commerce Department (EAR)

    • Criminal: $50,000 to $1,000,000 or up to 5 X the value of the export, whichever is greater per violation (range depends on the applicable law), up to 20 years imprisonment
    • Civil: loss of export privileges, fines up to $250,000 per violation or up to twice the value of the export

    Treasury Department (OFAC)

    • Criminal: up to $1,000,000 per violation, up to 10 years imprisonment
    • Civil: $55,000 to $250,000 fines (depending on applicable law) per violation