1 / 11

Implementation of a University Export Compliance Management Program

Implementation of a University Export Compliance Management Program. Adilia F. Koch. Export Compliance doesn’t come cheap. It’s the price of doing business in the international arena.

alessandra
Download Presentation

Implementation of a University Export Compliance Management Program

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Implementation of a University Export Compliance Management Program Adilia F. Koch

  2. Export Compliance doesn’t come cheap. • It’s the price of doing business in the international arena. • Price of non-compliance can result in negative publicity, put your endowment at risk, result in penalties & fines – • $250,000 to $1,000,000 • Criminal offenses can result in imprisonment

  3. Export Compliance Management Program: Where do you start? • Risk Assessment • Should be conducted under the direction of your Office of General Counsel to invoke the “Attorney-Client Privilege” and “Attorney Work Product” protection. • Identify most likely areas of high risk on campus: • Sponsored Research • Problematic Clauses • FRE language may be jeopardized • Procurement • Potential exports of technology with RFP or RFQs (foreign procurements) • Mailing and/or Shipping & Receiving • Export of hardware, software or technology

  4. Best Practices • Work with the process owners in developing best practices • Start with the higher risk areas • Conduct frequent assessments and audits to make sure its working • Outreach conduct campus process owner visits to work out the kinks

  5. Be ready to implement stop measures right away. • Once you become aware of potential areas of high risk, you will need to implement changes as quickly as possible to minimize the exposure. • Seek legal advice. • Violations? Disclosures? The folks in the Office of General Counsel will be your new best friends. • Have your wallet ready. . . you may also need to seek outside counsel.

  6. Awareness Training • Conduct Awareness Training • Group Sessions • One-on-one with faculty, if necessary • On-line training • Use various media’s depending on what works best for your campus and budget

  7. Assessment & Audit: Is your program working? • Don’t write a process or procedure you cannot implement • Internal audit review --- thumbs up! • Conduct regular assessments to ensure program is working • Audit vs. assessments --- they’re not the same

  8. Resources • Nunn-Wolfowitz Report • Export Compliance Management Program - BIS Seminar

  9. Contact Adilia F. Koch Director of Export Compliance California Institute of Technology

  10. Contact Info Adilia F. Koch Director of Export Compliance California Institute of Technology adilia.koch@caltech.edu Phone: (626) 395-4469 Fax: (626) 795-4571

  11. QUESTIONS • Q&A

More Related