The University of North Carolina at Greensboro (UNCG) recognizes that a critical component of its mission is supporting fundamental research as well as developing relationships and participating in the worldwide academic and business community to further the pursuit of knowledge. The University is committed to openness in its research activities and freedom of access and dissemination of information for the advancement of the common body of knowledge and scientific discoveries. As a participant in a diverse academic, research, and business community, UNCG is committed to complying with U.S. export controls laws and regulations that apply to its activities.

The Departments of Commerce, State, and Treasury administer the primary controls on exports of goods, commodities, and information.

  • The Department of Commerce regulates the export of items and information that have civil applications,
  • The Department of State regulates the export of items that have military applications or that relate to space, and
  • The Department of the Treasury enforces country-specific embargoes and financial sanctions on individuals, organizations and countries.

These agencies govern the shipment or transfer of export-controlled technical data, information, materials and equipment to destinations outside the United States, as well as the provision of access to certain export-controlled technical data, information, materials or equipment to non-U.S. persons within the United States (a “deemed” export). In addition, the Office of Foreign Assets Control (OFAC) regulations under the Department of Treasury impose sanctions and embargoes on transactions or exchanges with designated countries, entities and individuals. In certain circumstances, these agencies may require the University to secure a license before any items or information is exported to another country or shared with a foreign national. Getting a license takes time, potentially several months to a year, depending upon the circumstances. Contact the university ECO as soon as possible for help in determining the need for one.

Penalties for export control violations are substantial, including significant fines, debarment from participation in federal contracting, loss of export privileges, and in some cases imprisonment. In addition to these severe penalties, the potential reputational damage to an institution from violation of these laws could be difficult to repair, possibly resulting in lost opportunities for attracting world-class researchers and/or decreased access to research funding through private industry and government sources.

Civil Penalties Adjustment (06.07.16)

The Department of State is implementing “catch-up” adjustments to the maximum amounts of the civil monetary penalties (CMPs) it assesses.

For each violation of 22 U.S.C. 2778, an amount not to exceed $1,094,010 (previously $500,000);
For each violation of 22 U.S.C. 2779a, an amount not to exceed $795,445 (previously $500,000); and,
For each violation of 22 U.S.C. 2780, an amount not to exceed $946,805 (previously $500,000).