Kristen L. WormanAssistant General Counsel

Institutional Compliance Practice Group

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Export Controls:

Training, Travel, & ComputersCompliance Officer Meeting

October 15-16, 2013

The Texas A&M University System

Office of General Counsel

Training, Travel & Computers

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• Training• Offered by OGC• Presentation & Roundtable Discussion

• Travel• Know Before You Go!• What if you get stopped?

• Computers• How do export controls relate to IT?• What are the potential red flags?

Office of General CounselExport Controls Training

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WHO? Administrators, faculty, staff and students, as needed.

WHAT? Export Control Training

WHEN? Contact OGC to schedule a date.

WHERE? On your campus.

WHY ? To provide system members with an awareness of export control issues that affect campus and research activities.

HOW? One-hour presentation w/Q&A, followed by a roundtable discussion with member stakeholders (i.e., employees who are responsible for affected areas of activity).

Stakeholders & Functional Areas Affected

by Export Controls

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Stakeholders – Those employees who are responsible for a functional area affected by Export Controls.

Functional Areas/Activities Affected by Export Controls: Compliance Deemed Exports (International Faculty, Staff & Students) Financial Transactions/Purchasing Human Resources Immigration Information Technology (IT) International Visitors Research (Grants/Contracts/Equipment) Shipping Technology Commercialization Travel

International Travel & Export Controls:

Know BEFORE you go!

• What do I need to know?– Where are you going?– Who are you visiting?– What’s in your wallet?

• Or on your computer?– Who owns it?

• You or the University?– Do you really need to take that?– Will you need to access your files from outside the

US?– When are you coming back?

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International Travel & Export Controls:

US Customs & Border Patrol

• What happens if I get stopped?– US CBP may search your

luggage.– US CBP may ask you to

turn on / log into your laptop or other device.

– If you decline, US CBP may seize your device.

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Pre-travel Briefings

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• Export Control:Pre-travel Briefings

• Meet with individuals who are travelling.

• Talk about the risks.

• Have them sign an acknowledgment form.

IT & Export Controls:Computers, Smartphones & other

devices

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How do export controls apply to IT?• Export control regulations prohibit

exports to foreign countries, persons and entities – including exports of technology, software and technical data.

• Most technology, software and technical data are considered dual-use and fall under the EAR.

• BUT certain military-use or military-grade items are listed on the ITAR.

IT & Export Controls:Potential Red Flags

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•Travelling with IT devices Laptops Cell Phones Tablets Flash Drives

• Using non-University email accounts

•The Cloud Storing Data Exchanging Files

Questions

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