Temple University is fully committed to compliance with export control laws, a complex set of Federal laws and regulations that govern how physical items, technology, information and data may be exported from the United States or shared with foreign persons within the United States. Export controls are designed to protect U.S. national security, to further U.S. foreign policy goals, and to maintain U.S. economic competitiveness.
Research and other activities at Temple may be subject to export controls, including the International Traffic in Arms Regulations (ITAR), implemented by the U.S. Department of State, and the Export Administration Regulations (EAR), implemented by the U.S. Department of Commerce. The Office of Foreign Asset Control (OFAC), which is part of the U.S. Department of the Treasury, is responsible for administering and enforcing economic and trade sanctions against certain nations, entities, and individuals.
Export Control at Temple
The Office of the Vice President for Research (OVPR) is responsible for Temple University’s adherence to Export Control regulations. OVPR coordinates with stakeholders from around the university to ensure the university community has the resources, training and regulatory guidance necessary for export control compliance. These resources include:
- Restricted Party Screening (RPS): OVPR conducts RPS to determine if an organization, individual or country is restricted from receiving export-controlled items in addition to other restrictions that require review prior to engaging in a transaction. OVPR uses a software system that scans against U.S. government restricted party lists and other databases to identify such restrictions. All potential transactions with foreign persons and entities should be submitted for RPS using email@example.com.
- Export Control Training: OVPR offers training using the CITI Program. CITI training offers general export control training and tailored content for key functions of the university.
- Export Control Advisory Committee (ECAC): ECAC is comprised of representatives from key university functions that are responsible for export control compliance. ECAC advises OVPR on the implementation of policies and procedures, provides subject matter expertise based on each member’s area of responsibility and advises on Temple’s export control program operations.
Policies and Procedures
OVPR issued an Export Control Policy (available here) to provide the Temple community with an understanding of export control laws and the associated roles and responsibilities for maintaining Temple’s compliance. The policy approved by ECAC includes:
- Temple’s policy is to stay under the safe harbor of Fundamental Research Exclusion (FRE) as defined by ITAR (22 CFR § 120.11(a)(8)) and EAR (15 CFR § 734.8)
- Defined roles and responsibilities for faculty, principal investigators, administrative offices and other members of the Temple community to maintain compliance with export control laws in consultation with the Export Control Manager (contact below)
- The Institutional Official (Temple’s Vice President for Research) is the designated official responsible for export control at Temple and represents the university for any export control matters (e.g. self-disclosures, licenses)
- Any restricted research must be approved by OVPR and may require a technology control plan to ensure any export-controlled item at Temple is managed in accordance with the law.
Visit our FAQ page on Export Control as an additional resource and please don’t hesitate to contact firstname.lastname@example.org or Temple’s Export Control Manager Dwayne King (215-707-7819, email@example.com).