Export Control - Revision history

Mhurlocker at 17:08, September 21, 2026

2026-09-21T17:08:53Z

← Older revision		Revision as of 11:08, September 21, 2026
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	Policy No. '''8005'''<br />		Policy No. '''8005'''<br />
	Effective Date: '''12/18/12'''<br />		Effective Date: '''12/18/12'''<br />
	Revised Date: '''07/21/23'''<br />		Revised Date: '''08/08/26'''<br />
	Reviewed Date: '''07/09/24'''<br /><br />		Reviewed Date: '''08/19/26'''<br /><br />
	<big>'''Export Control Policy'''</big><br />		<big>'''Export Control Policy'''</big><br />
	==Authority==		==Authority==
	Statutes, regulations, and policies related to export controls include, but are not limited to:		Statutes, regulations, and policies related to export controls include, but are not limited to:
	*The Arms Export Control Act, [https://www.govinfo.gov/app/details/USCODE-2018-title22/USCODE-2018-title22-chap39 22 U.S.C. § 2751 ''et seq.'']		*Statutes, regulations, and policies related to export controls include, but are not limited to:
	*The Export Controls Act, [https://www.govinfo.gov/app/details/USCODE-2018-title50/USCODE-2018-title50-chap58 50 U.S.C. § 4801 ''et seq.'']		*# The Arms Export Control Act, [https://www.govinfo.gov/app/details/USCODE-2018-title22/USCODE-2018-title22-chap39 22 U.S.C. § 2751 ''et seq'']''.''
	*Assistance to Foreign Atomic Energy Activities, [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&node=pt10.4.810&rgn=div5 10 C.F.R. § 810]		*# The Export Controls Act, [https://www.govinfo.gov/app/details/USCODE-2018-title50/USCODE-2018-title50-chap58 50 U.S.C. § 4801 ''et seq'']''.''
	*The Export Administration Regulations (EAR), [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&tpl=/ecfrbrowse/Title15/15CVIIsubchapC.tpl 15 C.F.R. §§ 730-774]		*# Assistance to Foreign Atomic Energy Activities, [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&node=pt10.4.810&rgn=div5 10 C.F.R. § 810]
	*The International Traffic in Arms Regulations (ITAR), [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&tpl=/ecfrbrowse/Title22/22CIsubchapM.tpl 22 C.F.R. §§ 120-130]		*# The Export Administration Regulations (EAR), [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&tpl=/ecfrbrowse/Title15/15CVIIsubchapC.tpl 15 C.F.R. §§ 730-774]
	*The Foreign Assets Control Regulations, [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&tpl=/ecfrbrowse/Title31/31chapterV.tpl 31 C.F.R. §§ 500-599]		*# The International Traffic in Arms Regulations (ITAR), 22 [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&tpl=/ecfrbrowse/Title22/22CIsubchapM.tpl C.F.R. §§ 120-130]
	*[https://nebraska.edu/-/~~media~~/~~unca~~/docs/~~offices~~-and-~~policies~~/~~policies~~/~~policies~~/~~university~~-of-~~nebraska~~-~~travel~~-~~policy~~.pdf ~~University~~ of ~~Nebraska Travel Policy TO-01]~~		*# The Foreign Assets Control Regulations, [https://www.ecfr.gov/cgi-bin/text-idx?SID=8d0f469c37e6a5363c34f2fab9c97c26&mc=true&tpl=/ecfrbrowse/Title31/31chapterV.tpl 31 C.F.R. §§ 500-599]
	*UNMC Policy No. 8000, [[Compliance Program]]		*# [https://docs.nebraska.edu/unop/docs/Board of Regents/Policies/executive-memorandum/policy-on-university-sponsored-travel.pdf Executive Memorandum No. 25], Policy on Higher Risk University-Sponsored International Travel
	*UNMC Policy No. 8006, [[Code of Conduct]]		*# [https://docs.nebraska.edu/unop/docs/Board of Regents/Policies/executive-memorandum/disclosure-of-conflicts-of-interest-and-conflicts-of-commitment.pdf Executive Memorandum No. 36], Disclosure of Conflicts of Interest and Conflicts of Commitment
			*# [https://docs.nebraska.edu/unop/docs/Board of Regents/Policies/executive-memorandum/institutional-activities-involving-foreign-countries-of-concern.pdf Executive Memorandum No. 46], Institutional Activities Involving Foreign Countries of Concern
			*# UNMC Policy No. 8000, [[Compliance Program]]
			*# UNMC Policy No. 8006, [[Code of Conduct]]
	==Definitions==		==Definitions==

			=== '''Export Controls''' ===
			Export Controls are federal laws and regulations that govern shipments of physical commodities, technologies, services, and money to foreign countries. Export Controls also regulate disclosures of sensitive information, including certain research data, to Non-U.S. Persons located in the United States. In some cases, federal law may require the procurement of an export license or other authorization prior to carrying out an Export or Deemed Export.

	===Export===		===Export===
	Any item that is taken, transferred, or sent from the United States to a foreign destination is an export, including, but not limited to, commodities, software, technology, instrumentation, chemicals, biological materials, circuit boards, blueprints, design plans, retail software packages and technical information.<br />		Any item that is taken, transferred, or sent from the United States to a foreign destination is an export, including, but not limited to, commodities, software, technology, instrumentation, chemicals, biological materials, circuit boards, blueprints, design plans, retail software packages and technical information.<br />
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	#Corporations, business associations, and other organizations incorporated or otherwise authorized to do business in the United States.		#Corporations, business associations, and other organizations incorporated or otherwise authorized to do business in the United States.
	===Non-U.S. Person===		===Non-U.S. Person===
	A Non-U.S. Person is any natural or legal person who is not a U.S. Person. This includes UNMC Personnel, international organizations, foreign corporations, foreign governments (including diplomatic missions), and foreign universities.		A Non-U.S. Person is any natural or legal person who is not a U.S. Person. This includes UNMC Personnel, international organizations, foreign corporations, foreign governments (including diplomatic missions), and foreign universities.

	===Restricted Parties===		===Restricted Parties===
	Restricted Parties are entities and individuals subject to export sanctions under federal law. U.S. Persons are prohibited from exporting some or all items to Restricted Parties without an export license or other federal approval.		Restricted Parties are entities and individuals subject to export sanctions under federal law. U.S. Persons are prohibited from exporting some or all items to Restricted Parties without an export license or other federal approval.
	===Technology Control Plan===		===Technology Control Plan===
	A Technology Control Plan is a security protocol required for UNMC activities that involve export-controlled components. Technology Control Plans are used to manage physical and information security requirements, individual access controls to equipment and data, and project closeout procedures.		A Technology Control Plan is a security protocol required for UNMC activities that involve export-controlled components. Technology Control Plans are used to manage physical and information security requirements, individual access controls to equipment and data, and project closeout procedures.

	===UNMC Personnel===		===UNMC Personnel===
	UNMC Personnel include, for the purposes of this policy:		UNMC Personnel include, for the purposes of this policy:
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	This policy applies to all UNMC personnel, irrespective of appointment, compensation, or the location of the activity.		This policy applies to all UNMC personnel, irrespective of appointment, compensation, or the location of the activity.
	==Background ==		==Background ==
	The University of Nebraska Medical Center is committed to leading the world in transforming lives to create a healthy future for all individuals and communities through premier educational programs, innovative research and extraordinary patient care. To fulfill this mission, UNMC encourages partnerships and collaborations with the best and brightest individuals and institutions throughout the world. While the majority of research and global engagement may proceed without restrictions, the United States government imposes controls on certain exports to protect the spread of strategically important technology, services, and information to foreign countries and Non-U.S. Persons. The University recognizes the importance of these regulations and requires compliance with these export controls from every member of the UNMC community.		The University of Nebraska Medical Center is committed to leading the world in transforming lives to create a healthy future for all individuals and communities through premier educational programs, innovative research and extraordinary patient care. To fulfill this mission, UNMC encourages partnerships and collaborations with the best and brightest individuals and institutions throughout the world. While the majority of research and global engagement may proceed without restrictions, the United States government imposes controls on certain exports to protect the spread of strategically important technology, services, and information to foreign countries and Non-U.S. Persons. The University recognizes the importance of these regulations and requires compliance with these export controls from every member of the UNMC community.

	==Statement of Policy==		==Statement of Policy==
	All UNMC Personnel must comply with all applicable United States laws and regulations while teaching, conducting research, providing care, traveling internationally, or participating in other activities at or on behalf of UNMC. As such, UNMC Personnel are required to comply with the laws, regulations, and University of Nebraska policies governing the transfer of items, information, technology, software, and funds to destinations and persons outside of the United States, as well as to Non-U.S. Persons in the United States, including UNMC and/or Nebraska Medicine personnel.~~<br />~~		All UNMC Personnel must comply with all applicable United States laws and regulations while teaching, conducting research, providing care, traveling internationally, or participating in other activities at or on behalf of UNMC. As such, UNMC Personnel are required to comply with the laws, regulations, and University of Nebraska policies governing the transfer of items, information, technology, software, and funds to destinations and persons outside of the United States, as well as to Non-U.S. Persons in the United States, including UNMC and/or Nebraska Medicine personnel.

	UNMC Personnel will not engage in any export transaction unless all required licenses or other approvals are in place.~~<br />~~		UNMC Personnel will not engage in any export transaction unless all required licenses or other approvals are in place.

			There are no exceptions to this policy.

	~~There are no exceptions to this policy.~~
	==Responsible Parties==		==Responsible Parties==
	===Empowered Official for ITAR===		===Empowered Official for ITAR===
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	#Taking any other steps or compliance actions as directed by the Export Control Office.		#Taking any other steps or compliance actions as directed by the Export Control Office.
	==Violations==		==Violations==
	Failure to comply with this policy will result in corrective or disciplinary action as provided under UNMC Policy No. 1098, [~~https://wiki.unmc.edu/index.php/~~Corrective/~~Disciplinary_Action~~ Corrective and Disciplinary Action], including termination, dismissal, or exclusion from participation in federally funded activities.		Failure to comply with this policy will result in corrective or disciplinary action as provided under UNMC Policy No. 1098, [[Corrective/Disciplinary Action\|Corrective and Disciplinary Action]], including termination, dismissal, or exclusion from participation in federally funded activities. Failure to comply with US export law may result in significant criminal and civil penalties for both the individual in violation and UNMC.
	Failure to comply with US export law may result in significant criminal and civil penalties for both the individual in violation and UNMC.
	== Additional Information and Resources ==		== Additional Information and Resources ==
	*For more information about the applicability of export controls to specific activities (including research, shipping, and international travel), please contact the [mailto:exportcontrol@unmc.edu UNMC Export Control Office] (402-559-9328).		*For more information about the applicability of export controls to specific activities (including research, shipping, and international travel), please contact the [mailto:exportcontrol@unmc.edu UNMC Export Control Office] (402-559-9328).

Mhurlocker at 15:21, March 7, 2025

2025-03-07T15:21:51Z

← Older revision		Revision as of 09:21, March 7, 2025
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	</table>		</table>
	<br />		<br />
	[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[Disclosing Foreign Support and International Activities]] \| [[Health Care Vendor Interactions]] \| [[Credit Hour Definition]] \| [[Whistleblower]] \| [[Electronic Digital Signatures and Records]] \| [[Utilizing Generative AI]]<br />		[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[Disclosing Foreign Support and International Activities]] \| [[Health Care Vendor Interactions]] \| [[Credit Hour Definition]] \| [[Whistleblower]] \| [[Electronic Digital Signatures and Records]] \| [[Utilizing Generative AI\|UNMC AI Use Guidelines]]<br />
	<br />		<br />
	Policy No. '''8005'''<br />		Policy No. '''8005'''<br />

Mhurlocker at 19:42, March 6, 2025

2025-03-06T19:42:13Z

← Older revision		Revision as of 13:42, March 6, 2025
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	</table>		</table>
	<br />		<br />
	[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[Disclosing Foreign Support and International Activities]] \| [[Health Care Vendor Interactions]] \| [[Credit Hour Definition]] \| [[Whistleblower]] \| [[Electronic Digital Signatures and Records]]<br />		[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[Disclosing Foreign Support and International Activities]] \| [[Health Care Vendor Interactions]] \| [[Credit Hour Definition]] \| [[Whistleblower]] \| [[Electronic Digital Signatures and Records]] \| [[Utilizing Generative AI]]<br />
	<br />		<br />
	Policy No. '''8005'''<br />		Policy No. '''8005'''<br />

Mhurlocker: /* Additional Information and Resources */

2024-08-19T19:45:45Z

Additional Information and Resources

← Older revision		Revision as of 13:45, August 19, 2024
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	<br />		<br />

	This page maintained by [mailto:~~dpanowic~~@unmc.edu ~~dkp~~].		This page maintained by [mailto:mhurlocker@unmc.edu mh].

Mhurlocker at 13:45, July 11, 2024

2024-07-11T13:45:31Z

← Older revision		Revision as of 07:45, July 11, 2024
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	Effective Date: '''12/18/12'''<br />		Effective Date: '''12/18/12'''<br />
	Revised Date: '''07/21/23'''<br />		Revised Date: '''07/21/23'''<br />
	Reviewed Date: '''07/21/23'''<br /><br />		Reviewed Date: '''07/09/24'''<br /><br />
	<big>'''Export Control Policy'''</big><br />		<big>'''Export Control Policy'''</big><br />
	==Authority==		==Authority==

Mhurlocker at 17:53, August 14, 2023

2023-08-14T17:53:33Z

← Older revision		Revision as of 11:53, August 14, 2023
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	</table>		</table>
	<br />		<br />
	[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[Disclosing Foreign Support and International Activities]] \| [[Health Care Vendor Interactions]] \| [[Credit Hour Definition]] \| [[Whistleblower]]<br />		[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[Disclosing Foreign Support and International Activities]] \| [[Health Care Vendor Interactions]] \| [[Credit Hour Definition]] \| [[Whistleblower]] \| [[Electronic Digital Signatures and Records]]<br />
	<br />		<br />
	Policy No. '''8005'''<br />		Policy No. '''8005'''<br />

Mhurlocker: updated revised and review dates

2023-07-21T18:33:21Z

updated revised and review dates

← Older revision		Revision as of 12:33, July 21, 2023
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	Policy No. '''8005'''<br />		Policy No. '''8005'''<br />
	Effective Date: '''12/18/12'''<br />		Effective Date: '''12/18/12'''<br />
	Revised Date: '''11/09/20'''<br />		Revised Date: '''07/21/23'''<br />
	Reviewed Date: '''10/25/21'''		Reviewed Date: '''07/21/23'''<br /><br />
	<br /><br />
	<big>'''Export Control Policy'''</big><br />		<big>'''Export Control Policy'''</big><br />
	==Authority==		==Authority==

Mhurlocker: updated link to transporting and shipping internationally website.

2023-07-21T18:31:10Z

updated link to transporting and shipping internationally website.

← Older revision		Revision as of 12:31, July 21, 2023
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	*UNMC Compliance Hotline: 1-844-348-9584 or [https://secure.ethicspoint.com/domain/media/en/gui/52126/index.html www.nebraska.ethicspoint.com]		*UNMC Compliance Hotline: 1-844-348-9584 or [https://secure.ethicspoint.com/domain/media/en/gui/52126/index.html www.nebraska.ethicspoint.com]
	*[https://www.unmc.edu/academicaffairs/compliance/areas/export-control/index.html UNMC Export Control Website]		*[https://www.unmc.edu/academicaffairs/compliance/areas/export-control/index.html UNMC Export Control Website]
	*[https://~~info~~.unmc.edu/~~safety~~/~~Export~~-~~Shipping~~.html UNMC Transporting and Shipping Internationally website]		*[https://www.unmc.edu/academicaffairs/compliance/areas/export-control/transporting-shipping/index.html UNMC Transporting and Shipping Internationally website]
	*UNMC Policy No. 1098, [https://wiki.unmc.edu/index.php/Corrective/Disciplinary_Action Corrective and Disciplinary Action]		*UNMC Policy No. 1098, [https://wiki.unmc.edu/index.php/Corrective/Disciplinary_Action Corrective and Disciplinary Action]
	*UNMC Policy No. 8014, [https://wiki.unmc.edu/index.php/Disclosing_Foreign_Support_and_International_Activities Disclosing Foreign Support and International Activities]		*UNMC Policy No. 8014, [https://wiki.unmc.edu/index.php/Disclosing_Foreign_Support_and_International_Activities Disclosing Foreign Support and International Activities]

Dpanowic at 21:03, October 25, 2021

2021-10-25T21:03:36Z

← Older revision		Revision as of 15:03, October 25, 2021
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	Effective Date: '''12/18/12'''<br />		Effective Date: '''12/18/12'''<br />
	Revised Date: '''11/09/20'''<br />		Revised Date: '''11/09/20'''<br />
	Reviewed Date: '''11/09/20'''		Reviewed Date: '''10/25/21'''
	<br /><br />		<br /><br />
	<big>'''Export Control Policy'''</big><br />		<big>'''Export Control Policy'''</big><br />

Afaylor: updated UNMC Export Control Website link

2021-03-09T16:29:20Z

updated UNMC Export Control Website link

← Older revision		Revision as of 10:29, March 9, 2021
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	*For more information about the applicability of export controls to specific activities (including research, shipping, and international travel), please contact the [mailto:exportcontrol@unmc.edu UNMC Export Control Office] (402-559-9328).		*For more information about the applicability of export controls to specific activities (including research, shipping, and international travel), please contact the [mailto:exportcontrol@unmc.edu UNMC Export Control Office] (402-559-9328).
	*UNMC Compliance Hotline: 1-844-348-9584 or [https://secure.ethicspoint.com/domain/media/en/gui/52126/index.html www.nebraska.ethicspoint.com]		*UNMC Compliance Hotline: 1-844-348-9584 or [https://secure.ethicspoint.com/domain/media/en/gui/52126/index.html www.nebraska.ethicspoint.com]
	*[https://www.unmc.edu/academicaffairs/compliance/areas/export.html UNMC Export Control Website]		*[https://www.unmc.edu/academicaffairs/compliance/areas/export-control/index.html UNMC Export Control Website]
	*[https://info.unmc.edu/safety/Export-Shipping.html UNMC Transporting and Shipping Internationally website]		*[https://info.unmc.edu/safety/Export-Shipping.html UNMC Transporting and Shipping Internationally website]
	*UNMC Policy No. 1098, [https://wiki.unmc.edu/index.php/Corrective/Disciplinary_Action Corrective and Disciplinary Action]		*UNMC Policy No. 1098, [https://wiki.unmc.edu/index.php/Corrective/Disciplinary_Action Corrective and Disciplinary Action]