I.          Introduction

It is the policy of UNC Charlotte to comply with all United States export control laws and regulations, including those implemented by the Department of Commerce through its Export Administration Regulations (EAR), the Department of State through its International Traffic in Arms Regulations (ITAR), and those imposed by the Treasury Department through its Office of Foreign Assets Control (OFAC).

II.        Export Control Empowered Official and Committee

To carry out this policy, the Vice Chancellor for Research and Federal Relations will serve as the Empowered Official for export control matters for UNC Charlotte.  The Empowered Official will have overall responsibility for the University’s compliance with this policy. 

The Empowered Official will appoint, with approval of the proposed committee member’s supervisor, an Export Control Compliance Committee.  The members of the Committee will serve terms as determined by the Empowered Official.  The Committee will consist of UNC Charlotte faculty and staff with broad technical and business knowledge in fields that are most germane to export control issues.  The Office of Legal Affairs will provide legal services and advice to the Committee and to the Empowered Official.

The UNC Charlotte Facility Security Officer will provide services and advice to the Committee and to the Empowered Official, as needed, particularly with respect to the transfer of classified technical data in accordance with the National Industrial Security Program Operating Manual (NISPOM).

III.       Implementation

The Empowered Official will serve ex officio as Chair of the Committee.  The Committee will develop an Export Management Plan for UNC Charlotte.  The Export Management Plan will include procedures to ensure appropriate recordkeeping, training, internal reviews, screenings and any other processes that the Committee and the Empowered Official find necessary to ensure university compliance with the export control laws. The Empowered Official will be responsible for implementing and managing the Export Management Plan.