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Deemed Export: the release of export controlled technology to Foreign Persons in the U.S.

Empowered Official (EO): The EO, who must be a U.S. citizen, is empowered in writing to sign export license applications or other requests for export approval; understands the provisions and requirements of the various export control statutes and regulations, and the criminal liability, civil liability, and administrative penalties for violating the regulations; and has the independent authority to:

1. Inquire into any aspect of a proposed export, temporary import, or any other transaction within the scope of export control regulations.

2. Verify the legality of the transaction and the accuracy of any information to be submitted to a licensing or approval authority.

3. Refuse to sign any license application or other request for approval without retribution.

4. The EO, in conjunction with the Office of General Counsel as needed, is free of any encumbrances and operates under the full support of the University administration to initiate and pursue without interference any and all forms of investigation. All reports and circumstances receive careful consideration. Violation reporting to the appropriate governing body occurs when deemed necessary.

5. The EO may delegate some or all of the responsibilities of the EO to one or more designees in order to operationalize these tasks.

U.S. Person: Someone who is: 1) a U.S. citizen (whether born or naturalized); 2) a lawful permanent resident of the United States (e.g., “green card” holders); or 3) a protected individual as defined by 8 U.S.C. § 1324b(a)(3) (e.g., foreign persons such as refugees and asylees who are protected persons and considered U.S. persons for export control purposes). Corporations incorporated in the United States are U.S. persons for purposes of the ITAR and EAR. 

Foreign Person: Any person who is not a U.S. Person as defined above.           

����̽̽ Personnel: All University of Vermont employees, students, trainees, visitors, and other persons retained by or are working at the University who are involved in research, scholarly activities or other activities subject to export controls.

Without approval coordinated through the Office of the Vice President of Research, University Personnel and students may not engage in the transfer of export controlled information, equipment, technology, technical data, services or any other export controlled commodity to a foreign country, a Foreign Person, including a Foreign Person located within the United States through a Deemed Export. In addition, University Personnel and students may not conduct business in countries, or with entities or individuals that are the subject of United States Treasury sanctions.

The Vice President for Research (VPR) is the University Export Control Empowered Official (EO).

The procedures for implementing this policy are established by each department and each University unit.

Requests for an export license must be initiated and coordinated through the OVPR.

License reviews, application and approvals or denials operational responsibilities under this policy can take up to 3-6 months (or longer for OFAC) before a final determination is made. Each license is for a specific export transaction.

The Sponsored Project Administration Procedures implementing this policy can be found on the OVPR Research Integrity - Export Control Regulations webpage. 

Principal Investigators are responsible for ensuring that any additional faculty, staff and/or students working under the award are also aware of, and comply with, export control regulations.

If a University researcher needs to export any item, the research activity must pause until a review to determine if a license is required under the U.S. export control laws and regulations. Deemed Exports also require a license.

Alleged violations of this policy should be reported to the direct supervisor of the ����̽̽ Personnel. The supervisor then informs the Department Chair, Dean, the Director of Compliance Services, and the Vice President of Research. At their discretion, the appropriate Department Chair or Dean will determine the manner in which the alleged violation will be investigated. The Dean will consult with the Vice President for Research on the appropriate discipline, if any, to be imposed. For represented employees, provisions of any applicable collective bargaining agreement will apply.

• Directorate of Defense Trade Controls, U,S, Department of State
• ���ձʸ�’s&�Բ�����;Research Integrity - Export Control Webpage
• U.S. Export Administration Regulations can be found at: US Department of Commerce’s Bureau of Industry and Security (BIS)
• U.S. International Traffic in Arms Regulations can be found at: International Traffic in Arms Regulations (ITAR)

• Council on Government Relations (COGR) information on export controls
• International Traffic in Arms Regulations (ITAR)

Training/education related to this policy is as follows: