Overview of w88 and economic sanctions regulations

w88 controls

U.S. w88 and economic sanctions regulations exist to protect national security, foreign policy, and domestic economic interests. w88 regulations identify items, software, technology and services that may require an export license to transfer out of the U.S. Additionally, the release of controlled technology to a foreign national inside the U.S. is considered to be a "Deemed Exports | w88 mobile Integrity & Security | University of Nevada, Reno" to the individual's home country and is subject to the same licensing regulations.

w88 controls usually arise for one or more of the following reasons:

The nature of the w88 has actual or potential military applications or economic protection issues
Government concerns about the destination country, organization, or individual
Government concerns about the declared or suspected end use or end user of the w88

Licensing exports is one of the ways the federal government keeps track of who has access to sensitive items, information, technology, and software.

Economic sanctions

Economic and trade sanctions programs prohibit transactions with certain countries, institutions, and individuals in order to accomplish foreign policy and national security goals. Prohibited transactions are trade or financial transactions, and other dealings such as providing services, in which U.S. persons may not engage unless authorized or exempted by statute.

What does the University w88?

The University exports every day. We w88 ideas and information (technology) through innovation, creation, and sharing with students, staff, colleagues, and visitors on campus and in our research labs. Every time we ship or travel internationally, we w88 equipment, technology, and/or knowledge.

Common activities that might include w88 or economic sanctions considerations include:

Payment and receipt of compensation, honoraria, and contracts
Attendance at, or planning of, international conferences
Involvement of foreign students or collaborators in w88 in which controlled technology is used
Shipping or disseminating controlled items or information internationally
Provision of services to foreign nationals, including training in the use of controlled equipment in or outside the United States

Exclusions, Exemptions, and Exceptions

Recognizing the importance of academic freedom and sharing research results to the furtherance of knowledge, the federal government has excluded certain kinds of information from export controls. The majority of the University's activities are excluded from w88 and economic sanctions regulations. w88 regulations generally do not apply to information that is:

Because there are exceptions to these exclusions, always consult with Sponsored Projects if there is uncertainty about the w88 status of any University activity.

In certain situations, an activity controlled for w88 may be allowed without a license if a license exception applies to the activity. The conditions for license exceptions can be very narrow and must be strictly adhered to. The use of a license exception must be documented by the Office of Sponsored Projects and records kept for a minimum of five years.

Penalties for w88 Violations

Violations of w88 laws can result in both civil and criminal penalties, including fines and imprisonment. Although there is a maximum amount for a civil or criminal penalty, the actual penalty can be multiplied by the number of unauthorized exports. Even a single unauthorized export may result in multiple violations (e.g., export without a license, false representation on shipping documents, acting with knowledge of a violation, etc.).

Mitigating factors are assessed when assessing penalties. Mitigating factors include whether the disclosure of the violation was made voluntarily; whether the violation is an isolated incident or part of a pattern of continuing behavior; whether the institution had a compliance program in place at the time of the violation; whether steps were taken to improve the compliance program after the discovery of the violation; and whether the violation was due to inadvertence, mistake of fact, or a good faith misinterpretation of the laws.

In addition to civil and criminal penalties that may apply under applicable laws to individual University personnel/students and to the institution, violation of w88 laws and regulations may subject the violator to remedial or disciplinary action in accordance with the Board of Regents' Code, Title 2, Chapters 6, 8, and 10, and applicable institutional policies and procedures for misconduct, up to and including termination or dismissal.

Violation of w88 laws should be reported to the w88 Officer in Sponsored Projects. Most importantly, if there is a question as to whether an activity would be a violation of the w88 laws and regulations, contact the w88 Officer prior to engaging in the activity.

For more information and assistance

For more information, please contact the w88 Officer, Michele Dondanville, atmdondanville@unr.eduor (775) 784-6360.