Export Controls and Sanctions

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Export Controls and Sanctions




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Presentations text content in Export Controls and Sanctions

Slide1

Export Controls and Sanctions Compliance: International Travel and Shipping

Dan Runge

Export Compliance

Officer (ECO)

BSAG Meeting

6

December

2017

Slide2

UGA’s Office of Export Control

Timeline

Late 2012 to Early 2013 -

Institutional Effectiveness Review of

Office of Research

April and May 2013 - Fischer and Associates Export Control Assessment and Recommendations

Dec. 2013 – Fischer and Associates on

campus

July 2014 – Export Compliance Officer joins

UGA, Office of Export Control is created

Slide3

Office of Export ControlCompliance Areas

Economic and Trade

Sanctions

P

rohibitions

on transactions with restricted individuals, entities, countries, and economic sectors

Export Controls

U.S. laws and regulations that govern the

transfer of

controlled

items or information to foreign nationals,

entities,

and

countries

for reasons of national security and foreign policy

Slide4

Sanctioned and/or Embargoed Country Travel

Iran

U.S. Department of Treasury

p

ermission required

May take 6+ months to receiveEmbargo

limits what you can take with

you

Cuba

12

categories

of Treasury Department

authorized travel

e.g., professional meetings, professional research, study abroad

*

ECO decides if travel meets is allowed

Embargo

limits what you can take with

you

New prohibitions on financial transactions with

c

ertain entities (hotels, Old Havana shops, etc…)

Syria

U.S

. Department of Treasury permission

required

May take 6+ months to

receive

Embargo

limits what you can take with

you

Crimea region of Ukraine and Sudan

Sanctions limit activities and embargo limits exports

North

Korea

Travel

is

prohibited

Slide5

International Travel Approval

AP Travel Authority (TA) and OIE Travel Registry (TR)

TA required when travelling on behalf of UGA

TR required for international travel

approval

ECO reviews TR the day after submittedTaking UGA-owned items, sanction and embargo complianceRisk MitigationWhen traveling to sanctioned/embargoed destination, important to view TA and TR as more permissive than perfunctory

Regardless of destination, submit TR as early as possible

Provide

as much detail as possible on TR, especially purpose of travel and institutions visiting

Slide6

Export and Sanctions Issues in International Shipping

No Centralized International Shipping

What is being shipped and for what purpose?

What is the destination country and who is the recipient?

Best Practice

Contact ECO well in advance of shippingOnline request for international shipping review on Office of Export Control website

Slide7

International Shipping Risk Mitigation

Identifying export controlled items or information on

campus

Procurement

, Sponsored Projects, Material Transfer and Non Disclosure Agreements

ECO connects with Biosafety, ESD, Mail and Receiving ServicesOutreach to DepartmentsECO is assessing new international shipping review solutionsUniversity has a customs broker/freight forwarder/logistics firm that can assist

Slide8

Dan

Runge, J.D., LL.M.

Export Compliance Officer

drunge@uga.edu | 2-4188

Tucker 208

research.uga.edu/export-control


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