University of Massachusetts Lowell policy requires that all employees, visiting scientists, postdocs and students working at or for UML comply with U.S. laws and regulations. This includes compliance with U.S. export control laws and regulations applicable to the university’s operations.
Export controls are a complex and ever-changing set of laws and regulations that can impact the university in myriad ways. No UML personnel may transfer any items or technology contrary to U.S. export control laws and regulations, or UML Export Control Guidelines (pdf). It is critical that these requirements are complied with to prevent serious civil and/or criminal penalties for both the employee and the institution.
The regulations and laws governing exports are administered by several different federal agencies, including U.S. Departments of Commerce, State and Treasury. These agencies define exports as both:
- The actual shipment or transmission of a controlled item or technology out of the United States; or
- The transmission or release of controlled technology to a foreign person, even within the United States. (This can include simple verbal communication.)
In addition, export controls can be triggered by providing certain services to sanctioned countries, entities, or persons, or providing certain defense-related services to foreign entities or persons.
All UML employees with managerial or supervisory authority over foreign nationals, or with projects involving materials or technology subject to export controls, should view export-control compliance as an important part of their day-to-day responsibilities.
For further assistance, or if you have any questions, please contact Thomas Porro, the UML Export Control Compliance Manager, at Thomas_Porro@uml.edu or 978-934-3207.