Policy
The University of Chicago's Export Compliance Policy
It is the policy of the University of Chicago (‘UChicago’) that all of its employees, departments, divisions, domestic and foreign subsidiaries, and affiliates must comply with U.S. Government export control laws and regulations. No transactions are to be conducted by or on behalf of the University of Chicago contrary to U.S. export control laws and regulations.
University of Chicago employees with export responsibilities are required to have a working knowledge of export control laws and regulations, especially those governing their specific job functions, as well as a working knowledge of company export control policies and procedures.
The University of Chicago supports U.S. efforts to prevent proliferation of weapons of mass destruction. Special care must be taken to prevent any transaction with entities involved in the proliferation of weapons of mass destruction and prohibited activities involving missile, nuclear, chemical and biological warfare.
No transactions are to be initiated with individuals on the Denied Persons List, Special Designated Nationals or Terrorists List, or with any firms owned by or associated with those parties. Nor shall exports be made to parties on the Entity List.
Additionally, University of Chicago employees outside the U.S. may not re-export any commodity, technology, or software unless appropriate authorization has been obtained. This includes foreign produced items that are the direct product of U.S. technology and software or foreign made items that are subject to national security controls of the U.S. as designated by the CCL.
All of the University of Chicago personnel involved in exports and re-exports, traffic, and related functions are required to comply with the policies and procedures outlined in the University of Chicago’s Export Control Compliance Program & Manual maintained by University Research Administration. Under no circumstances will exports be made contrary to U.S. export regulations and laws.
It is the University of Chicago’s policy not to accept sponsored agreements or engage in contracts which contain publication or research restrictions in order to maintain its status with the Fundamental Research Exclusion (FRE).
Introduction
The University of Chicago (‘UChicago’) as an institution as well as individual principal investigators and administrators can be held liable for export control violations, with severe monetary penalties and sanctions resulting from non-compliance.
All research and administrative staff are strongly advised to read this General Guidance Memo and use it as an ongoing resource for complying with export controls. CLICK HERE (please make sure you are connected to UChicago's VPN)
If you have any questions or concerns about export controls, please contact the Export Control Office (ECO) at exportcontrol@uchicago.edu.
Export Control Compliance Program & Manual
For a comprehensive resource on the UChicago export control compliance program, please find our Export Control Compliance Program & Manual by CLICKING HERE (and please make sure you are connected to UChicago's VPN).
Export Compliance Training
It is UChicago’s intention to familiarize faculty and staff as comprehensively as possible on federal requirements regarding Export Controls. Export Compliance Training is available for free and on demand to all faculty and staff through CITI training and Workday LMS.
CITI Training:
The CITI Export Compliance Course offers comprehensive training over a number of modules that may be selected. You may select any Module of applicability and/or interest. Completion of the Module(s) will be kept on file with your CITI account.
Export Compliance Course: https://about.citiprogram.org/en/homepage
Instructions to access CITI Export Control training are available here.
University of Chicago Export Controls Training:
The Export Control team at UChicago has created the "Export Controls at UChicago" course in Workday LMS to better summarize and guide faculty and staff on export control concerns and best practices for campus activities.
Click here to access the course in Workday.
If you have any questions or concerns please contact:
Export Control Office
University Research Administration
exportcontrol@uchicago.edu
Export Compliance Course: https://about.citiprogram.org/en/homepage
Mike Vanderboom, JD
Export Control Officer
University Research Administration
772-702-8601
mvanderboom@uchicago.edu
Smita Singh
Assistant General Counsel
Office of Legal Counsel
773-702-7239
smitasingh@uchicago.edu