The Export Control Officer (ECO), is UM’s “Empowered Official”, and is responsible for providing oversight and guidance for all U.S. Export Control regulations, including, but not limited to, the ITAR, the EAR, and the Office of Foreign Assets Control’s (OFAC) Sanctions Regulations. 

University Personnel are permitted to use controlled items and technology in the conduct of research, provided such items and technology are not exported without appropriate authorizations. The use of ITAR-controlled items (“defense articles”) and technical data requires approval from UM’s ECO, and an approved Technology Control Plan (TCP). 

Unless approved in advance of purchase or receipt, the University does not permit the purchase or receipt of items or technical data that are listed on the U.S Munitions List (USML) and subject to the ITAR.  It is the responsibility of University Personnel to contact the ECO if proposing (e.g., in a grant application) or requesting to purchase or receive items or technical data that are controlled under the ITAR to facilitate ECO and Vice President for Research and Creative Studies review of the proposed purchase or receipt and gain approval. If the use of ITAR-controlled items or technical data is approved, such items or technical data will be subject to a Technology Control Plan (TCP). 

Shipping or hand-carrying any item or Technology, including items and Technology listed on the Commerce Control List (CCL) or classified as EAR99, to a comprehensively embargoed or sanctioned country or to a restricted end-user is prohibited, unless written authorization is received from the ECO. University Personnel must contact the ECO as early as possible when proposing to conduct activities, research, travel or collaborations involving comprehensively embargoed countries/regions. 

Financial transactions with individuals or entities from comprehensively embargoed countries or regions are prohibited unless approved in writing by the ECO and, if necessary, authorized by the U.S. government. Financial transactions with Restricted Parties or Specially Designated Nationals require review and approval by the ECO and may be prohibited. Before initiating financial transactions with a Foreign Person, you must ensure that the financial transaction is not with a Restricted Party, a Specially Designated National, or an individual in a comprehensively embargoed country.  

The anti-boycott provisions of the EAR prohibit U.S. Persons or businesses from participating in any non-U.S. sanctioned foreign government boycott. University Personnel who receive a request or agreement/contract that supports a restrictive trade practice or boycott imposed by another country, must promptly report the request to the ECO who, in turn, is obligated to report it to the Department of Commerce.  

In addition to this policy, all University Personnel must adhere to all applicable ITAR, EAR, and OFAC regulations as well as all terms outlined in the UM Export Control Manual.  If any University Personnel encounter questions or concerns relating to their obligations under this Export Control Policy, they may request assistance from the ECO for guidance and support. 

As appropriate, training covering individual and institutional Export Control compliance shall be required for all relevant University Personnel conducting research which is subject to Export Controls. Given the scope and complexity of the rules, University Personnel are encouraged to contact the ECO for guidance before engaging in any projects with a Foreign Person. Please examine our page, Activities Requiring Disclosure and Review, for more information.