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Kristen L. Worman Assistant General Counsel Institutional Compliance Practice Group

The Texas A&M University System Office of General Counsel. Export Controls: Training, Travel, & Computers Compliance Officer Meeting October 15-16, 2013. Kristen L. Worman Assistant General Counsel Institutional Compliance Practice Group. Training, Travel & Computers. Training

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Kristen L. Worman Assistant General Counsel Institutional Compliance Practice Group

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  1. The Texas A&M University System Office of General Counsel Export Controls: Training, Travel, & Computers Compliance Officer Meeting October 15-16, 2013 Kristen L. Worman Assistant General Counsel Institutional Compliance Practice Group

  2. Training, Travel & Computers • Training • Offered by OGC • Presentation & Roundtable Discussion • Travel • Know Before You Go! • What if you get stopped? • Computers • How do export controls relate to IT? • What are the potential red flags?

  3. Office of General CounselExport Controls Training

  4. Stakeholders & Functional Areas Affectedby Export Controls • Stakeholders – Those employees who are responsible for a functional area affected by Export Controls. • Functional Areas/Activities Affected by Export Controls: • Compliance • Deemed Exports (International Faculty, Staff & Students) • Financial Transactions/Purchasing • Human Resources • Immigration • Information Technology (IT) • International Visitors • Research (Grants/Contracts/Equipment) • Shipping • Technology Commercialization • Travel

  5. International Travel & Export Controls: Know BEFORE you go! • What do I need to know? • Where are you going? • Who are you visiting? • What’s in your wallet? • Or on your computer? • Who owns it? • You or the University? • Do you really need to take that? • Will you need to access your files from outside the US? • When are you coming back?

  6. International Travel & Export Controls: US Customs & Border Patrol • What happens if I get stopped? • US CBP may search your luggage. • US CBP may ask you to turn on / log into your laptop or other device. • If you decline, US CBP may seize your device.

  7. Pre-travel Briefings • Export Control: • Pre-travel Briefings • Meet with individuals who are travelling. • Talk about the risks. • Have them sign an acknowledgment form.

  8. IT & Export Controls:Computers, Smartphones & other devices • How do export controls apply to IT? • Export control regulations prohibit exports to foreign countries, persons and entities – including exports of technology, software and technical data. • Most technology, software and technical data are considered dual-use and fall under the EAR. • BUT certain military-use or military-grade items are listed on the ITAR.

  9. IT & Export Controls:Potential Red Flags • Travelling with IT devices • Laptops • Cell Phones • Tablets • Flash Drives • Using non-University email accounts • The Cloud • Storing Data • Exchanging Files

  10. Questions

  11. Contact Information • Kristen L. Worman • Assistant General Counsel • The Texas A&M University System • kworman@tamus.edu • (979) 458-6124

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