The Export Compliance Officer maintains responsibility for establishing, implementing, and enforcing University-wide export compliance policies, procedures, and guidelines designed to meet or exceed the requirements of the various federal laws governing the export of goods, technology, and information, including compliance with ITAR, EAR, and OFAC regulations.
The Export Compliance Officer for the University must balance international collaboration in the higher education market with the requirement for all U.S. persons, including persons at The Pennsylvania State University, to fully comply with all applicable federal export control regulations. To accomplish this goal, the University Export Compliance Officer must work closely with faculty, staff, and senior University Administration to establish, implement, and enforce guidelines and procedures designed to minimize the practical impact on University operations while maximizing the compliance efforts of the University. Colleges, campuses, departments, units, and administrative divisions may request an internal review and consultation with the University Export Compliance Officer to determine areas of concern within their areas of control and to develop compliance procedures to manage such matters effectively.
Export Compliance Plan
The development of a written compliance plan is a foundational step for an effective export compliance program. The Pennsylvania University has prepared an Export Compliance Program document (“ECP”) that outlines the University’s understanding of the impact of U.S. export control laws on the operations of an academic research institution like the University. The ECP has links to relevant forms, materials, government and private guidance documents, and other background information. The ECP also links internal University policies, procedures, and practices that have been implemented to facilitate institutional compliance with U.S. export control laws and regulations.
Export Compliance Plan
Customs and Importation Support
In addition to export control concerns for safety and security purposes, when traveling with or shipping items from one country to another, researchers should consider any applicable customs obligations or importation limitations of the relevant countries. In particular, objects used in research may need to be declared to a country’s customs officials upon entry. Certain items may require the payment of duties upon import into the U.S. or other countries. Temporary imports and exports may require a carnet or other customs documentation to avoid paying duties or taxes. Moreover, certain materials, including many biological materials not otherwise controlled for export or traditional safety/security purposes, may be restricted or require a license for entry or transport within certain locations due to livestock and/or agricultural concerns. For assistance with customs clearance and international shipment concerns, the University has designated R.L. Swearer as an authorized customs broker for Penn State. The contact information for this vendor can be found on Penn State’s purchasing website.
Export Compliance Team
Our export compliance professionals have experience evaluating, managing, and mitigating risks created by the intersection of federal export control laws and the operations of a multi-campus, internationally renowned institution of higher education and research. With both regulatory and technical backgrounds, we seek to help faculty, staff, and students to conduct their University activities in a manner compliant with the various laws, regulations, and guidelines which may impact our international efforts.