Cornell Export Controls Officer
Cornell’s Export Controls Officer supports WCM’s Export Controls Office with questions about and actions required for compliance with these federal regulations including:
- Evaluating research activity (e.g., sponsored project, technology transfer, international travel) for export controls conditions in coordination with ORSP, Innovation Partnerships, and other university units
- Assisting in the creation of a Technology Control Plan (TCP), if export controls apply to the research activity
- Obtaining appropriate federal licenses and other approvals for the export controlled research activity
- Advising on, and monitoring the completion of, required export controls training
Export Controls Review Committee
The WCM Export Controls Review Committee headed by the Export Controls Officer, reviews and approves Technology Control Plans as well as provides guidance to and feedback on the WCM Export Controls compliance program. Membership comes from across the university and research disciplines. The committee reviews policies and procedures to facilitate effective adherence to the federal regulations while maintaining WCM’s commitment to openness of research.
WCM Office Roles and Responsibilities
The Export Controls Office works in collaboration with various business units to ensure compliance with export control regulations. Below are the units that oversee various aspects of the export controls program:
Environmental Health and Safety (EHS)
EHS must review and approve the export of all goods based upon BIS regulations. EHS will also assist in the assessment of “Dangerous Goods” classification when necessary. Factors that may affect approvals include the type of Dangerous Good, the total value of requested items, the manufacturer recommended shipping temperatures, and the end use of the items. Exports may require permits, filings, or special provisions based on their classification. For this reason, members of the WCM community must consult with EHS and/or the Research Integrity Office to export consumables, data, technology, medical devices, or pharmaceuticals. The Export Controls Office and EHS have the authority to halt shipments that do not pass the export control review process. Please submit a Dangerous Goods Assessment form to EHS at least one (1) week prior to the anticipated export date. EHS will assess all items for Dangerous Goods classification and/or export restrictions. Forms and additional information can be obtained by clicking here.
Office of Sponsored Research Administration (OSRA)
OSRA reviews research proposals to identify situations which may trigger export control issues, such as, but not limited to, publication or foreign national restrictions, shipments of equipment overseas and deemed exports. OSRA negotiates research terms and conditions to ensure that WCM research projects qualify for the fundamental research exclusion to export control regulations.
Information Technologies and Services (ITS)
ITS requires minimum security requirements on all devices connecting to the WCM network. Such requirements are detailed in ITS policies, but include items such as system management software for security update distribution and remote wiping capabilities, encryption software, anti-virus/anti-malware software, and data loss prevention monitoring software. In addition, ITS has developed and implemented attestations which must be completed by all workforce members on an annual basis. Lastly, ITS has several monitoring tools and dashboards in place to detect inappropriate flow of data that may be in violation of existing policies. This includes firewalls, intrusion detection/prevention systems, data loss prevention, audit logging, and email security scanning, among others. For additional resources please refer to the following links:
Purchasing and Procurement
Purchasing Operations reviews the terms and conditions of vendor agreements for export control language that could trigger a review, as well as classification of the equipment or materials being purchased.
New vendors on Payment Requisitions e-forms are screened against restricted and denied party lists using Descartes Visual Compliance software. All new Foreign Person vendors are first sent to the Compliance Department to ensure proper backup and tax implications if any, before being routed to Accounts Payable via the e-form process.
Contact: Paul Brown, firstname.lastname@example.org
Center for Technology Licensing (CTL)
Institutional Animal Care and Use Committee (IACUC)
The IACUC oversees all research that involves vertebrate animals, conducts evaluations of the institution’s animal care and use program, and performs routine inspections of animal housing and procedure facilities.
Contact: Jennifer Akl, email@example.com
The Office of External Affairs has implemented a series of procedures to mitigate the potential of WCM soliciting or accepting gifts from foreign persons or entities which may damage the reputation of the institution or violate export control and foreign gift reporting regulations.