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Compliance Sub MenuDismiss

  Animal Care and Use Biohazardous Material Financial Compliance Drones Export Controls Human Subjects Protection Responsible Conduct

Export Controls

Compliance Export Controls
Export Controls
Overview
Forms Compliance Training

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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