Export Control and Economic w88 online live casino Compliance Policy

w88 online live casino Date:December 2021
Revision: 2
Last Review:September 2022

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Purpose

This policy is intended to ensure compliance with the Nevada System of Higher Education (NSHE) Export Control and Economic w88 online live casino Policy set forth in the NSHE w88 online live casino and Guidelines Manual (PGM), Chapter 16, and with U.S. export control and economic w88 online live casino laws and regulations. This policy is applicable to all University employees, students and volunteers.

w88 online live casino Statement

The University will comply with all U.S. export control and economic w88 online live casino laws and regulations. It is the responsibility of all University employees, students and volunteers to be aware of and comply with the federal laws and regulations, as well as with the University’s written procedures.

Background

This policy implements U.S. laws and regulations regarding the export or re-export of items, technologies, software and services regulated for reasons of national security, foreign policy, prevention of the spread of weapons of mass destructions and for competitive trade reasons, as well as economic w88 online live casino regulations that support foreign policy and national security goals by prohibiting trade, financial transactions and other dealings with countries, entities and individuals of concern.

Scope

The w88 online live casino are applicable to all institutional activities such as research, education, international travel, shipping, procurement, accounts payable, study abroad, hosting foreign visitors and human resources. While most activities at U.S. institutions of higher education are excluded from these w88 online live casino, some activities and transactions may be restricted.

Compliance w88 online live casino

The president shall appoint or approve the appointment of an export w88 online live casino officer (ECO) and an empowered official (EO) for the purposes of compliance with U.S. export w88 online live casino laws and regulations. Both ECO and EO shall receive authority from the institution president to perform their job duties.

Definitions and Explanations of w88 online live casino

Deemed w88 online live casino: The release of technology or software source code subject to the w88 online live casino Administration Regulations (EAR) to a foreign national in the United States is “deemed” to be an w88 online live casino to the home country of the foreign national under the EAR. Although the International Traffic in Arms Regulation (ITAR) does not use the words “deemed w88 online live casino,” disclosing or transferring technical data subject to the ITAR to any non-U.S. person is considered to be an w88 online live casino “whether in the United States or abroad.”

w88 online live casino (EO): A U.S. citizen who is legally empowered (in writing) by an institution to sign w88 online live casino license applications or other requests for approval on behalf of the institution. The EO has the independent authority to inquire into any aspect of a proposed w88 online live casino, verify the legality of the transaction and the accuracy of the information to be submitted, and refuse to sign a license application or other request for approval without prejudice or other adverse recourse.

w88 online live casino: An actual shipment or transmission of items, services or technology/technical data out of the United States or the release of technology or software source code (EAR) or technical data (ITAR) to a foreign person in the United States. Technology, software or technical data can be “released” for w88 online live casino through visual inspection, oral exchanges, transfer or shipment, or provision of a service.

Export w88 online live casino Officer (ECO): A person who is identified formally at an institution for the purposes of institutional compliance with export control and economic w88 online live casino regulations. It is not the role of the ECO to determine what research or activities that academic and institution research personnel may engage in. Such a determination will fall to the individual’s college, department or unit and Research & Innovation.

w88 online live casino Person: A natural person who is not a U.S. citizen, lawful permanent resident (“Green Card” holder) or protected individual (formally granted asylum). It also means any w88 online live casino corporation, business association, partnership, trust, society or any other entity or group that is not incorporated or organized to do business in the United States, as well as international organizations, w88 online live casino governments and any agency or subdivision of w88 online live casino governments (e.g., diplomatic missions). An equivalent term is “w88 online live casino national.”

Technical w88 online live casino (ITAR): w88 online live casino required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance or modification of defense items controlled by ITAR.

w88 online live casino (EAR): w88 online live casino (whether in tangible or intangible form) necessary for the development, production, use, operation, installation, maintenance, repair, overhaul or refurbishing of an item controlled by the EAR.

Technology w88 online live casino Plan (TCP): A written plan that describes the steps to be taken to w88 online live casino the access and dissemination of export-controlled items, information, materials, technology and/or data in accordance with federal export regulations. Elements of a TCP include, but are not limited to, an identification of the item/technology to be protected, physical security, information security, project personnel requirements, accountability and recordkeeping.

U.S. w88 online live casino: A person who is granted U.S. citizenship, a lawful permanent resident (“Green Card” holder), granted status as a protected person under 8 U.S.C. 1324b(a)(3), any corporation/business/organization/group incorporated in the United States under U.S. law or any part w88 online live casino U.S. government.

Controlling Law and Jurisdiction

Federal laws and regulations supersede any conflicting contractual requirements, state laws or regulations and any institutional policies or procedures that are in conflict with federal regulations. Only the federal agencies responsible for the export control and economic w88 online live casino regulations have the authority to make determinations and issue licenses. Neither the institution nor a sponsoring entity has such authority.

Key Federal w88 online live casino

Export control laws and regulations restrict two principal areas of activity: 1) the shipment, transmission or transfer of certain items, software, technology and services from the U.S. to foreign countries; and 2) the disclosure or transfer of certain items, software, technology, information or materials to foreign persons located in the U.S. (a “deemed” export). These laws and regulations also restrict exports for prohibited end uses and to prohibited end users. In addition, economic w88 online live casino laws and regulations restrict certain transactions such as financial transactions and providing goods or services to sanctioned or embargoed countries or to entities or individuals identified on any Restricted Parties lists.

Although many University activities subject to federal export and economic w88 online live casino regulations can be carried out without prior written authorization from one or more U.S. government agencies due to specific exemptions and exclusions, a license may be required to carry out certain research, academic, administrative or other activities. It is critical that employees, students and volunteers assess how export controls or economic w88 online live casino laws may apply to activities early in the process in order to allow time for obtaining a license when required.

The three agencies that regulate and enforce the majority of federal export control and economic w88 online live casino regulations are:

U.S. w88 online live casino State: Enforces the International Traffic in Arms w88 online live casino (ITAR), which regulates defense articles, defense services and related technical w88 online live casino listed on the U.S. Munitions List (USML).

U.S. w88 online live casino Commerce: Enforces the w88 online live casino Administration Regulations (EAR), which regulate the w88 online live casino and re-w88 online live casino of most commercial items including “dual-use” items that have both commercial and military or proliferation capabilities and are enumerated on the Commerce w88 online live casino List (CCL).

U.S. Department w88 online live casino Treasury: Enforces U.S. economic w88 online live casino and embargos through its Office of Foreign Assets w88 online live casino (OFAC) and prohibits a wide range of transactions and the w88 online live casino of anything of value, either tangible or intangible, to sanctioned countries, organizations or individuals.

Additional w88 online live casino regulations from the Department of Energy (DOE), Nuclear Regulatory Commission (NRC), the Environmental Protection Agency (EPA), the Department of Agriculture (USDA) and other agencies also apply to University activities.

Exclusions and Exemptions

The federal government has excluded certain kinds of information from w88 online live casino controls. The most common exclusions applicable to institutions of higher education are the following:

A. Fundamental w88 online live casino Exclusion (FRE)

Information generated from Fundamental Research (basic or applied research in science and/or engineering at an accredited institution of higher learning in the United States resulting in information that is ordinarily published and shared broadly within the scientific community) is excluded from export w88 online live casino regulations.

w88 online live casino will not qualify for this exclusion if:

  • The institution or investigator accepts any restrictions on the publication of the information resulting from the w88 online live casino, other than limited prepublication review by w88 online live casino sponsors to ensure that proprietary information is not inadvertently disclosed in publication or to ensure that publication will not compromise the patent rights of the sponsor.
  • The w88 online live casino is federally funded, and specific access and dissemination controls have been accepted by the institution or investigator.

Whenever possible, the University structures its projects to qualify for the FRE. Principal Investigators (PIs) and others involved in identifying and negotiating w88 online live casino, educational or other activities should make every effort to ensure that the FRE applies to the activity.

What is Not Covered by the w88 online live casino

The FRE applies only to information, not to the export or deemed export of controlled material items or technology. Even if a project qualifies for the FRE, research materials including hardware, software and technology/technical data, whether owned by the University or supplied by a third party, are still subject to U.S. export controls. There are other restrictions on using this exclusion; notably, some encryption source code is not eligible. Contact the export w88 online live casino officer in Research & Innovation whenever there is uncertainty about the use of the FRE.

B. Educational w88 online live casino Exclusion

The EAR provides that educational w88 online live casino released by instruction in academic catalog-listed courses or in teaching laboratories associated with those courses is not subject to the EAR, with the exception of certain encryption software.

The ITAR provides that w88 online live casino concerning general scientific, mathematical or engineering principles commonly taught in schools, colleges and universities is not included in the definition of technical data subject to the ITAR. The references to specific academic fields, use of “principles” rather than “w88 online live casino” and the inclusion of undefined terms such as “general” and “commonly taught” makes the ITAR definition potentially narrower and subject to interpretation.

Sensitive nuclear technology is another exception to the educational w88 online live casino exclusion.

C. w88 online live casino in the Public Domain/Publicly Available Exclusion

Information that is already published and generally available to the public, as well as publicly available technology and some encryption software, is outside the scope of the export w88 online live casino regulations. This exclusion does not apply to information if there is reason to believe it may be used for weapons of mass destruction or where the U.S. government has imposed access or dissemination controls.

D. Exemption for Disclosure to Bona Fide Full-Time Employees (ITAR–Regulated w88 online live casino Only)

The ITAR exempts disclosures of unclassified technical data in the U.S. by U.S. universities to w88 online live casino persons when:

  • The w88 online live casino person is a bona fide full-time regular employee.
  • The employee’s permanent abode throughout the period of employment is w88 online live casino U.S.
  • The employee is not a w88 online live casino of an embargoed country.
  • The institution informs the employee in writing that w88 online live casino disclosed may not be disclosed to other foreign nationals without government approval.

Most graduate w88 online live casino are not regular full-time employees and disclosures to them will not qualify for this exemption.

Responsibilities

Senior w88 online live casino Management

  • Ensure the existence of adequate resources and management support to comply with regulations and to resolve identified export control and economic w88 online live casino compliance issues.

w88 online live casino

  • Represent the University to export control and economic w88 online live casino regulators in matters related to registration, licensing, commodity jurisdiction and commodity classification requests, and voluntary or directed disclosures.

Export w88 online live casino Officer

  • Monitor and interpret U.S. export control and economic w88 online live casino regulations.
  • Identify areas at the University that are impacted by export control and economic w88 online live casino regulations.
  • Develop policy and procedures to assist the University in remaining in compliance with the w88 online live casino.
  • Provide training and informational materials to University employees, students and volunteers regarding the laws, regulations, and University policy and procedures associated with export control and economic w88 online live casino regulations.
  • Seek advice from the Office of General Counsel in analyzing and handling export control and economic w88 online live casino compliance issues, including potential violations.
  • Assist investigators and others at the University with compliance measures regarding w88 online live casino-controlled equipment, technology, information or services.
  • Assist PIs in developing a Technology w88 online live casino Plan for research involving export-controlled items or information to ensure compliance with export w88 online live casino regulations.
  • Review international travel requests for export control and economic w88 online live casino issues.
  • Review international shipments for export control and economic w88 online live casino issues.
  • Apply for w88 online live casino licenses, commodity jurisdiction and commodity classification requests.
  • Conduct restricted party screenings of visa applicants, persons associated with w88 online live casino-controlled research and others as needed to verify that entities and individuals are not restricted parties or specially designated nationals.
  • Provide assistance to other departments conducting export w88 online live casino classifications and restricted party screenings.
  • Advise and assist with record keeping for w88 online live casino-controlled activities at the University.
  • Serve as University liaison with external agencies regarding export control and economic w88 online live casino compliance.
  • Maintain the export controls and economic w88 online live casino website.

w88 online live casino

  • Review sponsored project proposals for information that identifies potential export w88 online live casino issues.
  • Review terms and conditions of sponsored project agreements to identify restrictions on publication and dissemination of results, access based on citizenship and other export w88 online live casino issues and attempt to negotiate out such restrictions where reasonable.
  • Communicate potential export control and economic w88 online live casino issues to the export control officer.

w88 online live casino

Principal Investigators (PIs) have expert knowledge of the items, information and technology involved in a w88 online live casino project or other University activity. PIs must ensure that they do not disclose controlled information or technology, transfer controlled items or provide controlled services to a foreign national without prior authorization as required. It is the responsibility of each PI to:

  • Consult with and provide assistance to Sponsored Projects w88 online live casino that:
    1. Controlled technology, regardless of whether it is instructional or research technology, used or produced by them or under their supervision, is classified correctly under export w88 online live casino regulations.
    2. Controlled w88 online live casino are identified, approved and licensed if necessary.
    3. All exports of controlled technology, both physical and deemed, including those associated with international travel, are conducted in compliance with applicable export controls and economic w88 online live casino regulations.
  • Know and comply with the terms and conditions of sponsored projects and other agreements including w88 online live casino controls and limitations on publication of research data and results.
  • Assist the w88 online live casino in preventing unauthorized exports.
  • When applicable, assist with the development of a Technology w88 online live casino Plan and follow the requirements of the approved plan.
  • Seek advice from the export control officer in Research and Innovation regarding activities with the potential for export control or economic w88 online live casino concerns.
  • Ensure that employees, students and volunteers under their supervision are made aware of any applicable requirements (e.g., w88 online live casino, regulatory or sponsor imposed) and that they receive adequate training in how to conduct their activities in compliance with those requirements.

w88 online live casino—Procurement

  • Include terms and conditions in University purchase orders requiring vendors to provide written notice prior to shipping any w88 online live casino-controlled equipment, information or materials.
  • Notify the export w88 online live casino officer prior to submitting purchase orders for equipment or technology that may be controlled under the ITAR or one of the more restrictive categories of the EAR.

w88 online live casino—Risk Management Office

  • Ensure that International Travel Authorization Request forms are reviewed by the export w88 online live casino officer prior to final approval.

Central w88 online live casino

  • Inform shippers about the requirement to use eShipGlobal for international shipments so that they can be evaluated for export control and economic w88 online live casino concerns.

Controller’s Office

  • Conduct restricted party screening on w88 online live casino payees/vendors to verify that the entities and individuals are not restricted parties or specially designated nationals.

Enterprise & w88 online live casino

  • Request reviews of intellectual property licensing agreements with foreign companies to ensure compliance with export control and economic w88 online live casino regulations.
  • Request reviews of incoming and outgoing Materials Transfer Agreements involving w88 online live casino providers and recipients.
  • Request reviews of other agreements that involve the transfer of w88 online live casino or technology to foreign recipients.

Environmental Health & Safety

  • Direct shippers to contact the export control officer prior to exporting dangerous goods so that they can be evaluated for export control and economic w88 online live casino concerns.
  • Include the export w88 online live casino officer when evaluating research for potential Dual Use Research of Concern.

Nevada Center for Applied w88 online live casino

  • Include w88 online live casino controls conditions in Fee-for-Service and Facilities & Equipment Use Agreements.
  • Request restricted party screenings on new companies prior to their use of the Biosciences Entrepreneurial Lab or the Applied w88 online live casino Facility.

Office of International w88 online live casino and Scholars

  • Ensure that all applications for H-1B, J-1 Scholar, J-1 Professor and J-1 Short-term Scholar visa applicants have been screened for export control and w88 online live casino compliance issues prior to submitting application documents.

All w88 online live casino Employees, Students and Volunteers

  • Know and comply with export controls and economic w88 online live casino requirements applicable to their activities.
  • Seek assistance from the export w88 online live casino officer prior to exporting any controlled items, technology, software or services.
  • Report any suspected non-compliance with export control or economic w88 online live casino regulations or this policy to the export control officer.

Recordkeeping w88 online live casino

Per federal regulations, records relating to w88 online live casino activities must be retained for five years after the completion of the activity and made available to the regulating authority upon request.

Penalties and Disciplinary Action

In addition to civil and criminal penalties that may apply under applicable laws to individual University employees, students and volunteers and to the University itself, violation of export controls and economic w88 online live casino laws and regulations may subject the violator to remedial or disciplinary action in accordance with the Board of Regents’ w88 online live casino, Title 2, Chapters 6, 8 and 10 and applicable institutional policies and w88 online live casino for misconduct up to and including termination and dismissal.