Export control laws are federal regulations that govern how certain information, technologies, and commodities can be transmitted overseas or to a foreign national on U.S. soil. The scope of the regulations is broad: they cover exports in virtually all fields of science, engineering, and technology and apply to research activities regardless of the source of funding. Failure to comply with these laws can have serious consequences, both for the institution and for the individual researcher. Potential penalties include fines and possibly imprisonment. It is thus critical for UConn researchers to understand their obligations under these regulations and to work with Research Integrity and Compliance Services to ensure that the University is in compliance.
The International Traffic in Arms Regulations (ITAR) regulate defense articles, services, and related technical data that are identified on the Munitions Control List. They are administered by the Department of State. The Export Administration Regulations regulate the export of dual use items, i.e. items with both military and commercial applications, identified on the Commerce Control List. They are administered by the Department of Commerce. The Office of Foreign Assets Control Regulations (OFAC Regulations) regulate economic trade with foreign countries and administer the statutory economic trade sanctions imposed against several foreign countries. They are administered by the U.S. Department of the Treasury, through the Office of Foreign Assets Control.
The Export Control Materials are hosted on the UConn Storrs OVPR website.
If you have any questions about Export Control, please email exportcontrol@uconn.edu.
- Issuance, Review and Execution of the Project Agreement: Because UConn Storrs and UConn Health are separate fiscal entities, a project agreement needs to be executed before funds can be transferred between the two campuses. After the lead organization has received its award, a project agreement is prepared by UConn Storrs SPS unit or UConn Health’s SPS unit. This agreement is emailed to the subawardee’s corresponding unit for review and execution.
Note: The project agreement must be signed by authorized signatories of both parties. Pls are not authorized to sign.
- Award/Fund Setup: Separate project funds are set up at the lead and sub’s campuses. Prior to fund set-up, all compliance-related approvals should have been obtained, e.g., Institutional Review Board (IRB)/Stem Cell Research Oversight (SCRO)/Institutional Animal Care and Use Committee (IACUC)/Institutional Biosafety Committee (IBC).
- Invoicing: Before invoices can be paid, they must be approved by the lead campus’s principal investigator.
- Amendments: Competitive project periods often span multiple budget years. If the sponsoring agency awards funds on a budget year basis, issuance and execution of amendments will be necessary to next year’s funding after it has been released to the lead organization by the sponsor.
- Carryover of Funding and No-Cost Extensions: Carryover of funds and no-cost extensions (NCE) are not authorized without the lead’s written approval. If needed, at least sixty (60) days prior to the end date of the current budget period the PI(s) should seek approval for any carryover or NCE requests.
- Award Closeout: So that awards may be closed out in accordance with sponsor requirements, final invoices will normally be required no later than 45 days following the termination date of the award project period.
For assistance with cross campus subawards,
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