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A Real-World Warning on Export Compliance

April 23, 2013

Why the process matters

April 18, 2013 | If you’ve wondered whether export compliance is simply a matter of red tape, our colleagues at the University of Massachusetts Lowell can tell you that it’s very serious business.

As a result of export violations, the Center for Atmospheric Research at UMass Lowell recently entered into a settlement agreement with the U.S. government. The institution agreed to a fine of $100,000 that may be waived if no further violations occur during a two-year probationary period. UMass Lowell also agreed to make the details of the violations and the terms of the settlement agreement public information, as an example for others to learn from.

This example hits very close to home.  Atmospheric science is not immune to export compliance issues.

In 2007, the UMass Lowell center exported two instruments to the Pakistan Space and Upper Atmosphere Research Commission in violation of export control laws. These two instruments are designated as EAR99 on the U.S. Commerce Control List. EAR99 items generally require no export license.  However, if the proposed shipment is to an embargoed country, to an end user of concern, or in support of a prohibited end use, then an export license may be required and could be denied. In this case, the foreign recipient is an end user of concern.

All international shipments of export-controlled items, documents, and technical data on media that originate from UCB facilities must be routed through Mailing Services, which will take full responsibility for shipping and export compliance.

EXPORTING SIMPLY AND SAFELY

To start the process, contact Mailing Services advising of an upcoming shipment.  Mailing Services will then undertake an export evaluation and provide you with a time frame in which the upcoming shipment will be scheduled.

Got questions? Along with the background websites below, you can contact Linda (ext. 2-2889) for assistance reviewing proposed exports and to walk you through the compliance process.

Mailing Services is registered with AES Direct through the US Census Bureau, and can file any paperwork required for export.   We are here to serve the shipping needs of all Departments on the CU Campus, as long as all required information is provided.

Call (303) 492-2443 or 492-2445 for shipping estimates or other information.

Visit the Mailing Services Website to print out an IN (invoice) or request a pickup, at:  http://www.colorado.edu/facilitiesmanagement/distmail/mailing/index.html

Tags: Export Controls
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