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Ethical Compliance

Graduate Students

Export Controls: Penalties for Non-Compliance

PENALTIES FOR VIOLATIONS CAN APPLY TO BOTH INDIVIDUALS AND THE INSTITUTION

Can result in:

• Loss of "exporting" privileges (usually for 30-90 days) could halt university's normal activities,

• Puts federal funding at risk -- for the university and for the individual,

• Negative media attention

State Department (ITAR)

• Criminal: up to $1M per violation and up to 10 years in prison

• Civil: seizure and forfeiture of articles, revocation of exporting privileges, fines of up to $500K per violation

Commerce Department (EAR)

• Criminal: $50K-$1M or five times value of export, whichever is greater, per violation, up to 10 years in prison

• Civil: loss of export privileges, fines $10K-$120K per violation

Treasury Department (OFAC)

• Criminal violations: up to $1,000,000 per violation, up to 10 years imprisonment

• Civil penalties: $12,000 to $55,000 fines (depending on applicable law) per violation. UCLA recently fined for an OFAC violation involving an activity with Iran.

• Violation of specific sanctions laws may add additional penalties

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