Roles and Responsibilities

Export Compliance Committee (ECC)

The ECC facilitates regulatory compliance by developing and implementing procedures to screen proposals and projects for compliance with export control laws and regulations. The ECC consists of university stakeholders and subject matter experts from the following areas:

  • Office of Research and Sponsored Programs
  • Grants Accounting
  • IT Security
  • Compliance
  • Purchasing
  • Human Resources
  • Office of Global Affairs (OGA)
  • Information Security Office
  • Environmental, Health & Safety (EHS)

The ECC members work closely with the ECC Chair, PIs, sponsored programs managers, and  other University stakeholders in identifying export control issues and providing support for their resolution. The Export Compliance webpage provides a listing of current ECC members and contact information.

The ECC works with faculty, staff and project teams as appropriate in their area of responsibility to identify and resolve export control issues by assisting with the:

  • Review of proposal and agreement terms and the determination of the applicability of export controls to a given international activity;
  • Identification of factors that can negate the Fundamental Research Exclusion and in negotiating the deletion of such restrictions, if possible;
  • Conducting restricted party screenings

Export Compliance Committee Chair

The Export Compliance Committee Chair (“ECC Chair”) is responsible for directing and monitoring the University’s export control compliance program, including developing, implementing, and updating the Ohio University Export Control Compliance Manual which outlines the procedures, standards, and guidelines for compliance with federal export control laws and regulations. As needed, or upon request, the EEC Chair will assist the OHIO community in export control assessments, determine compliance obligations with respect to OHIO activities involving foreign persons or international activities under applicable export control laws and regulations, and determine the applicability of the Fundamental Research Exclusion (“FRE”) or other exclusions provided by law.

The ECC Chair, or designee, will convene meetings as needed and call upon other faculty or staff for subject matter expertise as appropriate. The University will assist any member of the OHIO community in complying with U.S. export control laws and regulations, including through the ECC, but primary responsibility for compliance with such laws and regulations rests with the faculty, researcher, or other member of the University community involved in the specific activity.

The ECC Chair will also assist with Training, Restricted Party Screening (RPS), Technology Control Planning and consult with OHIO’S Office of Legal Affairs on export control matters as appropriate. The ECC Chair will be responsible for ensuring that periodic self-assessments of the University’s compliance with export control laws are conducted by the ECC.

Export Compliance Officer

The Export Compliance Officer (“ECO”) reports to the Vice President for Research and Creative Activity and has the authority and the responsibility for the implementation of the procedures set forth in this Export Compliance Manual, including:

  • Serving as a principal point of contact for agencies with regulatory or enforcement authority under the export control regulations;
  • Signing and submitting license applications and other requests for approval on behalf of the University;
  • Reviewing and approving technology control plans;
  • Managing the University’s registrations, including user account provisioning and access to online accounts with regulatory agencies;
  •  Coordination of Principal Investigators (PIs) and the ECO on export-controlled activity to ensure that export-controlled material and information are secured, that export licenses and other export authorizations are obtained when necessary, and that export controlled technology is safeguarded and documented within a Technology Control Plan (TCP);
  • Coordination of ECO to ensure that all export control determinations related to international work is communicated to all stakeholders including but not limited to PIs, project negotiators and administrators assigned to the research, and project team members, as appropriate.

Empowered Official

Empowered Officials are responsible for authorizing license applications and other approvals required for compliance with export control laws and regulations, and they serve as representatives of OHIO, by acting as points of contact with federal agencies having export control jurisdiction. The Vice President for Research and Creative Activity serves as the Empowered Official.

Employee Expectations and Individual Responsibility

All Principal Investigators, administrators, supervisors, coordinators, and others involved in export regulated activities or with authority over foreign persons or projects involving exportcontrolled information or hardware have the responsibility to ensure export control compliance by overseeing the compliance efforts in their areas of administrative responsibility and for partnering with the ECO, ECC, and Empowered Officials in implementing the procedures set forth in this Manual.

To meet their obligations for compliance, each person must:

  •  Understand their export control obligations;
  • Successfully complete annual training to identify and assess export control issues;
  • Determine, prior to initiation of research or exporting information or material, whether the activities are subject to export control laws or regulations;
  • Be aware of red flags and other export control indicators, and documenting such information on any internal compliance or assurance forms;
  • Periodically review applicable international activities (travel, communication, shipping, etc.) to ensure compliance with export control laws and regulations;
  • Ensure the researchers, staff, and students involved in the project are briefed on their export control obligations and applicable Technology Control Plans; and
  • Understand that any informal agreements or understandings entered into with a sponsor may negate the Fundamental Research Exclusion or other key exclusions and impose export control obligations on the project team.

The University assists members of the OHIO community in complying with U.S. export control laws and regulations. However, primary responsibility for compliance with such laws and regulations rests with the faculty, researcher, or other member of the OHIO community involved in the specific activity, as that individual is the most knowledgeable and maintains the control of the potential export.

Individual Responsibility

All OHIO faculty, staff, students, visiting faculty and scientists, postdoctoral fellows, affiliates, contractors, and volunteers affiliated with OHIO (“OHIO representatives”) must conduct their affairs in accordance with U.S. export control laws and regulations. While compliance with all applicable legal requirements is imperative, it is equally important to maintain an open research environment that welcomes the participation of researchers from around the world as part of OHIO’s mission. To maintain this balance, OHIO representatives must be familiar with the U.S. export control laws and regulations, including applicable exclusions and exemptions, as they relate to their responsibilities. Depending upon the nature of their activities and/or job functions, OHIO representatives may be required to participate in formal training identified by 
OHIO Empowered Officials, employees’ supervisors, or export control team members.

Office of Research and Sponsored Programs

In accordance with University Policy XX.XXX Export Compliance, upon receipt of a notice of export-controlled equipment, items, technology or information, the Office of Research and Sponsored Programs (ORSP) will work with the Principal Investigator (PI) to document the analysis of the applicability of export control laws and regulations utilizing the Export Control Decision Tree referenced above. Furthermore, ORSP will assist in the analysis of the applicability of any exclusion or exemption prior to the start of any work on the project involving such controlled items. ORSP will provide monthly reports to the ECC on activity.