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Export Controls

Introduction

Weill Cornell Medicine (WCM) is fully committed to compliance with all United States export control laws and regulations.  Export controls and trade sanctions regulate and restrict the release of critical technologies, software, equipment, chemical, biological materials and other materials, and services to foreign nationals and foreign countries for reasons of foreign policy and national security. All members of the WCM community—including faculty, students, staff, volunteers, visitors, contractors, and consultants—must comply with all export control laws and regulations.

Detailed information about WCM's export controls compliance program can be found below in the Guidelines section.

Export Controls Officer

The Office of Research Integrity oversees all aspects of WCM’s compliance with export control laws and regulations.  The Export Controls Officer has been granted the authority to seek export licenses from the relevant government agencies in support of WCM activities.  The Export Controls Officer is also authorized to provide support and guidance to members of the WCM community for export control compliance.

Contact: Thomas Blair, thb2002@med.cornell.edu

Office Roles and Responsibilities

The Export Controls Officer 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 Officer 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.

Contacts: Abigail Nixon, aeo2003@med.cornell.edu; Kitty Ng-Yeung, kyn4001@med.cornell.edu

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.  

Contacts: Aleta Gunsul, alg2047@med.cornell.edu; Stephen Hunt, sjh2004@med.cornell.edu

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:

Contact: Brian Tschinkel, brt2008@med.cornell.edu; Vinay Varughese, vinay@med.cornell.edu

Finance
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.

Accounting

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, pmb2004@med.cornell.edu

Center for Technology Licensing (CTL)

Any biological, data or technology shipments must have a Material Transfer Agreement (MTA) in place prior to shipment.

Contact: Quintin Schwab, qis2@cornell.edu

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, jea2012@med.cornell.edu

Human Resources

WCM Human Resources completes a post offer background check, including restricted party screening, on all new hires.

Contacts: Jeanie Huang, jch2003@med.cornell.edu; Susan Shevlin, sshevlin@med.cornell.edu

External Affairs

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.

Contacts: Gloria Kao, glkao@med.cornell.edu; Rhonda Holdip, rhh2003@med.cornell.edu

Special Precautions for Travel to High Risk Countries, including China, Russia, and Venezuela

High risk countries—namely China, Russia, Venezuela, Cuba, Iran, North Korea, and Syria—represent foreign entities that pose a high risk of compromise or other security attack against the USA.Take only the minimum number of electronic devices needed for your trip. You are to leave your WCM devices at home.

  • Take only the minimum number of electronic devices needed for your trip. You are strongly encouraged to leave your WCM devices at home.
  • Submit a request to borrow a laptop from the Library. Some high risk countries, including China, prohibit the import of encrypted devices, and taking a standard WCM laptop into the country poses a real risk of your device being compromised.
  • If possible, you should not access websites containing sensitive information (e.g., financial, health, etc.) while connected to public Wi-Fi networks.
  • Chinese officials often block the use of VPN software to protect your privacy on the internet, but you can attempt to use VPN software from ITS to access WCM resources while abroad.
  • Keep electronic devices in your possession; hotel staff often have access to in-room safes.
  • If you are traveling to China, Russia, or Venezuela, you must complete the Electronic Export Information (EEI) filing. Instructions for completing the EEI can be found here: Job Aid: Export Control Travel Filing
  • To make the EEI filing, each individual traveler needs to know the export control classification number (ECCN) for all items being reported. The ECCNs for devices can be found in the documents below, according to device type:

Policies and Forms

Guidelines

  • This manual provides detailed information on WCM's export controls compliance program, including definitions, processes, and resources.

FAQs

No FAQs available.

Announcements

March 26, 2021: Update on the U.S. federal government's regulatory requirements for all persons planning personal or business travel to China, Russia, or Venezuela. Click here for full memo.

January 19, 2021: Be advised that the federal government has imposed reporting requirements on all persons travelling to China, Russia, or Venezuela. Under the Export Administration Regulations (EAR), every person that travels to China, Russia, and Venezuela, must report all items carried into the above countries. Click here for full memo.

Office Contacts

Thomas H. Blair, JD
Chief Research Compliance Officer, Research Integrity Officer
Phone:
(646) 962-2100
Omar Perez, JD
Manager, General Research Compliance
Phone:
(646) 962-4059