Roles and Responsibilities
The following represents language developed in collaboration with and for the Texas A&M research community. (PDF)
Export control laws regulate the conditions under which certain information, technologies, and commodities can be transmitted to foreign persons or entities in the United States or abroad. In addition, export control laws and regulations restrict or prohibit the transaction of business with certain countries, persons, and entities that have been sanctioned by federal agencies as a threat to important U.S. interests. Most exports do not require specific approval from the federal government. Certain exports, however, require a license. Others are prohibited.
Texas A&M University, the Institution
It is the policy of Texas A&M University to comply with United States export control laws and regulations while maintaining an open research environment that welcomes the participation of researchers from around the world.
All University employees and students, visiting scientists, postdoctoral fellows, and other persons retained by or working at or for the university must conduct their affairs in accordance with United States export control laws and regulations. While compliance with applicable legal requirements is important, it is equally important to maintain an open research environment that welcomes the participation of researchers from around the world as part of the University’s mission. To maintain this balance, university personnel must be familiar with United States export control laws and regulations, including important exclusions and exemptions, as they relate to their responsibilities and research. Depending upon the nature of job activities and functions, University personnel may be required to participate in formal training as determined by the university’s empowered official(s) and/or an employee’s supervisor. There are severe institutional and individual sanctions for violations of export control laws and regulations, including the loss of research funding, loss of export privileges, as well as criminal and civil penalties.
All University employees with managerial or supervisory authority over foreign persons or projects involving controlled information or controlled physical items should view export control compliance as an important part of their day-to-day responsibilities. University employees with managerial or supervisory authority over foreign persons or projects involving controlled information or controlled physical items are required to take the Export Controls Office's basic export control online training course at least once every two years.
The(VPR) is the university’s “empowered official” for all purposes relating to applicable federal export control laws and regulations. The empowered official is responsible for license applications and other approvals required for compliance with export control laws and regulations, and serves as the university’s representative and point of contact with such agencies. The empowered official is the university official authorized to sign license applications and other authorizations required by export control laws and regulations on behalf of the university and to bind the university in any proceedings before government agencies with export control responsibilities. The VPR is the university official with final responsibility for compliance with export control laws and regulations.
Export Controls Office
The Export Controls Office (ECO), in cooperation other appropriate offices, is responsible for directing and monitoring the university’s export control compliance program, record keeping, and implementing procedures and/or guidelines to comply with federal export control laws and regulations, including developing, implementing, and updating an export control compliance program manual.
When requested, the ECO will assist employees in export control assessments to determine export control compliance obligations with respect to university activities involving foreign persons or entities or international activities and to determine the applicability of any exclusions provided by law. The ECO also assists with and conducts restricted party and technological screening using the export control screening software licensed by the university.
Sponsored Research Services
Sponsored Research Services (SRS), in coordination with the ECO, is responsible for developing and implementing procedures to screen proposals and projects for compliance with export control laws and regulations. SRS works closely with the ECO, principal investigators, and members of The Texas A&M University System as appropriate to identify export control issues related to research and provide support for their resolution.