Roles and Responsibilities
Empowered Official – The identified Empowered Officials for the University with the authority
to apply for export licenses on behalf of the University, to verify the legality of transactions and
to stop export transactions.
Assistant Vice President for Research Compliance and Policy - Reports to the Vice President of
Research, Graduate Studies and Economic Development and is responsible for all aspects of
research compliance, including export control.
University Export Control Officer (“UECO”)– The individual responsible for managing the
University’s Export Compliance Program, conducting export training, assisting with export
determinations and applications for export authorizations, and conducting internal audits.
Training Coordinator – The Training Coordinator for Research Compliance and Policy, in
coordination with the UECO, develops an export curriculum, training packages, organizes
seminars and arranges for guest speakers.
Program Coordinator, Senior – Assists the UECO with administrative tasks.
Office of Research and Contract Analysis (“ORCA”) – Coordinates review of contract and grant
Sponsored Projects Services (“SPS”) – Coordinates review of proposals and grants with
Departmental Export Compliance Administrators (“DECA”) – All UA units who engage in
research and other activities that involve controlled technologies are required to designate an
individual in their unit who will be responsible for assisting faculty and other research personnel
with the identification of export issues and managing export compliance at the department or
project level. The DECA must be trained and will assist with reviewing contracts and grants to
identify export restrictions, screening foreign nationals and assisting PIs with item classification.
Export Compliance Council (“ECC”) –The Assistant Vice President for Research Compliance
and Policy shall chair the Export Compliance Council and membership will include the Export
Control Officer, the Training Coordinator and, by invitation, designated departmental export
compliance administrators as well as such other UA employees as the Council deems necessary.
The Council confers regularly and meets (or teleconferences) no less than once per quarter to
review and update policies and procedures for export control compliance.
Export Working Group (“EWG”) – The Export Working Group is comprised of departmental
export compliance administrators and chaired by the UECO. The purpose of the EWG is to
develop export processes for approval by the ECC and devise implementation plans.
Principal Investigator (“PI”)– The principal investigator is the individual who bears primary
responsibility for all essential aspects of the work being carried out, including technical aspects
and completion of programmatic work, compliance with government, sponsor, and university
policies and regulations, fiscal stewardship of sponsored funds, and all administrative
requirements of the project. He/she must understand and comply with any export restrictions
and also ensure that all personnel working on his/her projects are also informed. The PI has
primary responsibility for export compliance on his/her projects which includes the following
1. prior to commencing any research, to review and cooperate with the Office of Vice
President for Research, Graduate Studies and Economic Development (“OVPR”) to
determine whether any technical information or technology involved in their research is
subject to the export control law or regulations and if so, whether any exclusion is
available under the export control regulations;
2. to re-evaluate that determination before changing the scope or adding new staff to the
project to determine if such changes alter the initial determination;
3. to make export determinations far enough in advance to obtain an export license from the
appropriate agency, if required and available; and
4. to ensure that foreign nationals are excluded from access to restricted data or technology
until the availability of an exemption or exception has been determined, or an export
license has been obtained.
The University will assist PIs in assessing the application of such regulations, but primary
compliance responsibility rests with the Principal Investigator of the research.
Researchers and staff – All personnel who devote effort to restricted projects must read and
follow the Technology Control Plan and seek guidance from the UECO or PI as necessary.
Facilities Security Officer (“FSO”) – The FSO supervises and directs security measures
necessary for implementing the applicable requirements of the National Industrial Security
Program Operating Manual (“NISPOM”) and related Federal requirements for classified
information and serves as the point of contact with the Department of Defense Industrial Security