managers must ensure that their staff receives regular training on export control issues to meet the university obligations under the laws. F. Researchers Principal Investigators, Co-Investigators, – The researchers are the people who have expert knowledge of the type of information and technology involved in a research project or other university activity, such as presenting at conferences, and discussing research findings in class with fellow researchers or collaborators. The PIs are those that have control over negotiating the terms of an external funding agreement, and more specifically, restrictions on publication or dissemination, and foreign citizen participation. PIs must ensure that they do not disclose controlled information or transfer controlled articles or services to a foreign national without prior authorization as required. To meet their obligations, PIs: Must understand their obligations under export controls, and participate in regular trainings to help them identify export control issues. Must help the SRS and the Office of Compliance & Ethics to classify the technology involved in the research or other university activity, and identify foreign nationals that may be involved. If export control is likely, the PI should initiate the process of clearing foreign national participation well in advance to ensure that a license is obtained in a timely manner, or proper measures are taken to isolate foreign nationals from participation. If the PIs undertake an export controlled project, they must the students and other researchers involved in the project of their obligations under export controls. The PI cooperates with the Office of Compliance & Ethics in developing the TCP; it is the responsibility of the PI to follow and implement the TCP. If the project requires foreign travel, the PI ensures that he or she, and all researchers, students and staff working under his or her supervision on a specific project abide by and fill in the Foreign Travel Checklist attached as Appendix C. G. Educators Support Staff, IT Staff, Human Resources Officers – Other educators play a substantial role in ensuring export compliance by providing technical support, administrative, IT, or human resource services. It is important that these employees receive a general overview of export controls to appreciate the intricacy of compliance and identify potential areas where their specific knowledge and skills may improve compliance. H. Students U.S. and foreign students who are engaged in export controlled research must be briefed on export controls and sign an acknowledgement that they understand their obligations under
managers must ensure that their staff receives regular training on export control issues to meet the university obligations under the laws. F. Researchers – Principal Investigators, Co-Investigators, The researchers are the people who have expert knowledge of the type of information and technology involved in a research project or other university activity, such as presenting at conferences, and discussing research findings in class with fellow researchers or collaborators. The PIs are those that have control over negotiating the terms of an external funding agreement, and more specifically, restrictions on publication or dissemination, and foreign citizen participation. PIs must ensure that they do not disclose controlled information or transfer controlled articles or services to a foreign national without prior authorization as required. To meet their obligations, PIs: Must understand their obligations under export controls, and participate in regular trainings to help them identify export control issues. Must help the SRS and the Office of Compliance & Ethics to classify the technology involved in the research or other university activity, and identify foreign nationals that may be involved. If export control is likely, the PI should initiate the process of clearing foreign national participation well in advance to ensure that a license is obtained in a timely manner, or proper measures are taken to isolate foreign nationals from participation. If the PIs undertake an export controlled project, they must the students and other researchers involved in the project of their obligations under export controls. The PI cooperates with the Office of Compliance & Ethics in developing the TCP; it is the responsibility of the PI to follow and implement the TCP. If the project requires foreign travel, the PI ensures that he or she, and all researchers, students and staff working under his or her supervision on a specific project abide by and fill in the Foreign Travel Checklist attached as Appendix C. G. Educators – Support Staff, IT Staff, Human Resources Officers Other educators play a substantial role in ensuring export compliance by providing technical support, administrative, IT, or human resource services. It is important that these employees receive a general overview of export controls to appreciate the intricacy of compliance and identify potential areas where their specific knowledge and skills may improve compliance. H. Students U.S. and foreign students who are engaged in export controlled research must be briefed on export controls and sign an acknowledgement that they understand their obligations under
RIT%20Export%20Compliance%20Program%20%20%28Rev%20March%202016%29.docx