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
