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Policy No: 2102
Responsible Office: Research Compliance and Assurance
Last Review Date: 01/12/2023
Next Required Review: 01/12/2028
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International Shipping
1. Purpose
This policy is to specify the University’s commitment to compliance with all Export Control, Trade, and Transportation Sanctions laws and regulations as they apply to international shipments, and to outline processes and procedures for institutional review of international shipments prior to shipment. US export regulations may require an export license or license exception based on the item (including technical data), shipping destination, value, or end user. Failure to obtain an export license when required could result in fines of $250,000 to $1million per violation and prison time for criminal convictions.
2. Applicability
This policy shall apply to all individuals in the University General Division who ship internationally under the auspices of conducting University business.
3. Definitions
Shipper: Individual shipping on behalf of the 秘密研究所.
Shipping company: Entity providing shipping services.
4. Policy Guidelines
The University will comply with all U.S. federal Export Control, Trade Sanction, and Transportation regulations when shipping items, commodities, equipment, materials, substances, biologics, artifacts, software, and/or technical data (collectively, “items”) to an international destination/party. These laws govern:
- Items that are exported (i.e. transferred) out of the country;
- Includes exporting to Canada;
- Includes passing thru Canada (i.e., in a vehicle) from a U.S. destination such as Alaska. This would be considered an export;
- Shipments which require an export license or other authorization;
- Shipments which require customs declarations, filings, and other documentation;
- Shipments which require hazardous materials protocols.
Individuals shipping on behalf of the University must ensure all necessary institutional reviews are completed prior to submitting an international shipment request form. Intuitional reviews may include (not inclusive) Research Compliance, Safety and Environmental Compliance, Sponsored Programs, General Counsel, or legal interest in the items to be shipped.
Automated Export System (AES) filing for shipments valued over $2500 or those that require an export license are required under the Foreign Trade Regulations. The Export Control Officer can review and advise on available license exceptions.
5. Procedures
The International Shipping Review Process is found here. Shippers must follow this process prior to shipping any item internationally.
Prior to initiating an international shipment, complete an International Shipment Review request form via REDCap. The form will automatically route to the Office of Research Compliance and Assurance for review, and you may be contacted for additional information. The shipper will be notified when approval is granted.
Questions related to the International Shipping Review Process should be directed to the Office of Research Compliance and Assurance, see staff contact information.
5.1 Record Keeping
All shipping records including pro forma invoice, airway bill, export filings and associated communications are required to be maintained for a period of five years from the date of the export. Request a copy of relevant documents from your shipper or print them when using an online application. Your shipper (such as DHL, FedEx or UPS) will not keep copies of shipping records for you.
5.2 Sanctions for Non-Compliance
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- U.S. Government agencies strictly enforce export control and trade sanctions regulations through substantial civil and criminal penalties, federal debarment, and revocation of export privileges. Agencies have full audit and oversight authority;
- Consequences for violations by university personnel, employees, students, visitors, courtesy appointments, and any other individual conducting research, academic, operational, or business activities on behalf of USA can include discipline up to and including termination and dismissal, depending on circumstances.
6. Enforcement
Violations of the policy may subject the individual to corrective action or other sanctions as deemed appropriate by the Vice President for Research and/or Office of Research Compliance and Assurance. The policy will be enforced through periodic monitoring for compliance.
7. Related Documents
7.1 Export Controls: International shipping webpage