Kristen L. WormanAssistant General Counsel
Institutional Compliance Practice Group
1
Export Controls:
Training, Travel, & ComputersCompliance Officer Meeting
October 15-16, 2013
The Texas A&M University System
Office of General Counsel
Training, Travel & Computers
2
• 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?
Office of General CounselExport Controls Training
3
WHO? Administrators, faculty, staff and students, as needed.
WHAT? Export Control Training
WHEN? Contact OGC to schedule a date.
WHERE? On your campus.
WHY ? To provide system members with an awareness of export control issues that affect campus and research activities.
HOW? One-hour presentation w/Q&A, followed by a roundtable discussion with member stakeholders (i.e., employees who are responsible for affected areas of activity).
Stakeholders & Functional Areas Affected
by Export Controls
4
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
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?
5
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.
6
Pre-travel Briefings
7
• Export Control:Pre-travel Briefings
• Meet with individuals who are travelling.
• Talk about the risks.
• Have them sign an acknowledgment form.
IT & Export Controls:Computers, Smartphones & other
devices
8
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.
IT & Export Controls:Potential Red Flags
9
•Travelling with IT devices Laptops Cell Phones Tablets Flash Drives
• Using non-University email accounts
•The Cloud Storing Data Exchanging Files
Questions
10
Contact Information
11
Kristen L. Worman
Assistant General Counsel
THE TEXAS A&M UNIVERSITY SYSTEM
(979) 458-6124