Bureau of Industry and Security (BIS) Export Enforcement has published new resources for the academic community: a compliance note on voluntary self-disclosure trends and a compendium of export compliance resources.
The compliance note, Trends in Voluntary Self-Disclosures Related to Academia to Inform Improvements to Export Compliance Plans, details conduct commonly disclosed by academic institutions over the past ten years that constitutes export control violations. The document also highlights actions universities can take to address and prevent these violations, including enhanced training programs and improved internal controls.
The Compendium of Resources offers a comprehensive guide to export compliance tools, including informational and vetting resources, BIS-specific resources, and examples of recent enforcement actions. These tools (reproduced below) should help academic institutions integrate export control requirements into everyday operations for professors, students, staff, and visitors, which in turn helps minimize the risk of violations.
Together, the compliance note and the compendium of resources build on the efforts of the Academic Outreach Initiative, first announced in June 2022. The Academic Outreach Initiative is intended to help academic institutions maintain an open, collaborative research environment in a way that also protects them from national security risk, and it includes strategically prioritized engagement, the assignment of outreach agents to prioritized institutions, background briefings, and trainings.
Resources:
This page allows users to search various U.S. Government screening lists, including the Bureau of
Industry and Security’s (BIS) Entity List and the Department of the Treasury Office of Foreign Assets Control’s SpeciallyDesignated Nationals (SDN) List, by filling in specific fields, such as name, address, country, and source.
The U.S. Government’s National Counterintelligence and Security Center’s (NCSC) Safeguarding Science initiative is an outreach program designed to protect research and innovation in emerging technologies. It aims to raise awareness about potential risks involving these technologies, such as potential misuse or theft, and help stakeholders secure technology in thefields of AI, bioeconomy, autonomous systems, quantum computing, and semiconductors.
The Australian Strategic Policy Institute’s China Defence Universities Tracker is a tool that identifies Chinese universities thatare engaged in defense research, training defense scientists, collaborating with the military, cooperating with defense industry conglomerates, and are involved in classified research.
The Named Research Organizations list is composed of research organizations and institutions that pose the highest risk to Canada’s national security due to their direct or indirect connections with military,
national defense, and state security entities. Under the Government of Canada’s Policy on Sensitive Technology Research andAffiliations of Concern, all researchers involved in activities funded by a
research grant from the Government of Canada that advance a sensitive technology research area must terminate affiliationswith, or receipt of funding or in-kind support from, these entities to continue with the research grant.
The Trade Integrity Project (TIP), an initiative of the UK-based Open-Source Centre, has launched a website that monitors military and dual-use trade with Russia. The TIP website specifically focuses on trade in Common High Priority List (CHPL)items and displays entities that have shipped CHPL items to Russia since 2023, according to publicly available trade data. BIS, in cooperation with the European
Union, Japan, and the United Kingdom, has developed the CHPL, which currently includes 50 items
identified by six-digit Harmonized System Codes that Russia seeks to procure for its weapons programs. The list of CHPL items can be found here.
Offered by the University of Leiden (Netherlands), VOSviewer is a software tool for constructing and visualizing bibliometric networks. These networks may include journals, researchers, or individual publications, and they can be constructed based oncitation, bibliographic coupling, co-citation, or co-
authorship relations. The tool can map specific terms to identify all universities cited in published works on that topic.
The BIS website provides an easy-to-use tool to help navigate the EAR. The contextual search option and the in-product help allow the user to easily maneuver through the many categories that make up the
Commerce Control List (CCL).
This tool provides instructions on how to determine the correct Export Control Classification Number (ECCN) for an item subject to the EAR.
SNAP-R allows users to submit and track export license applications, commodity classification requests, reexport license applications, and license exception agricultural commodity (AGR) notifications online.
This link provides guidance on deemed exports, which refers to the sharing or release of controlled technology or source code to a foreign person within the United States.
BIS provides a framework to establish successful export compliance programs that align with U.S. regulations. Theseguidelines highlight the necessary integration of compliance measures into daily operations, with the goal of protecting national security.
Frequently asked questions related to the rules implementing export controls on semiconductor manufacturing equipment (SME), advanced computing items, and supercomputers. The FAQs also address ongoing national security concerns that itemscovered by these rules can be used for military modernization and other applications, such as the development and production of weapons of mass destruction (WMD).
The White House’s Office of Science and Technology Policy (OSTP) published guidelines for academic research institutions that address the risks posed by strategic competitors to the U.S. research and development enterprise. The guidelines include arequirement that covered individuals complete training on export controls and compliance. Covered individuals can stay up to date on the EAR by attending in- person seminars, signing up to receive regulatory updates, reviewing learn and support modules, and watching training videos online. The seminars, modules, and videos cover different aspects of the EAR, including encryption export controls and fundamental research, as well as how to submit a license
application. There is also an option to contact a counselor if there are further questions.
“Don’t Let This Happen to You!” is a compendium of case examples highlighting BIS criminal and administrative enforcementefforts. The updated version includes new enforcement cases involving a
voluntary self-disclosure by an academic institution, violations of the antiboycott regulations, firearms export violations, exportviolations related to China and Iran, and non-compliance with a BIS settlement agreement. Exporters are encouraged to reviewthe publication, which provides useful illustrations of the type of conduct that gets companies and universities in trouble.
BIS actively encourages the submission of Voluntary Self-Disclosures (VSDs) from parties who suspect they may have violated the EAR. VSDs serve as a strong indication of a party’s commitment to complying with U.S. export controlrequirements. There is a “fast-track” resolution policy for VSDs that involve only minor or technical infractions—i.e., those without aggravating factors. Parties can submit VSDs electronically to BIS_VSD_INTAKE@bis.doc.gov.
A collection of documents that outline BIS’s guidelines and procedures for enforcing export control laws and regulations, provide clarity on how violations and penalties are handled, and outline guidance for
industry on how to comply with export controls and look for red flags when selling or transferring controlled items, software, and technology.
Address and contact information for the Office of Export Enforcement’s nine Field Offices and three Resident Offices.
This policy memorandum established the Academic Outreach Initiative, an effort by BIS to partner with select academic research institutions through strategically prioritized engagement, the assignment of. “outreach agents,” and the provision of training and background briefings, with the goal of protecting against those who attempt to harm our collective national security.
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