Since September 11, 2001, government agencies have dramatically increased the investigation in and successful prosecution of export regulation violations. The penalties for these violations can be very severe, including personal liability, monetary fines, and imprisonment. However, government agencies assign great weight to voluntary self-disclosures as a mitigating factor. All confirmed violations will be documented and handled in accordance with University policy.
Any individual who suspects a violation has occurred must immediately notify an Empowered Official. The Empowered Official (if not the UECO) shall then immediately notify the UECO, who will then consider the violation before proposing a course of action. If selfdisclosure is chosen, the UECO will make the required notification to the appropriate government agency.The UECO will conduct an internal review of the suspected violation with the advice, assistance, and counsel from the OUC, and/or Empowered Officials. Once the review is complete and the CLO and SVCR concur, the UECO will provide the government agency with a supplementary letter with a thorough narrative account of:
- the project’s description and background;
- a description of the suspected violation;
- which items and controlled categories were involved;
- dates on which the violations occurred;
- which countries were involved;
- the citizenship of the individual involved;
- an explanation of how the violation occurred;
- any corrective actions taken; and
- University’s commitment to export controls compliance.
Once the initial notification and supplementary letter have been sent, UECO shall comply with the government agency’s instructions. Export controls agencies, as well as experts in the field, agree that voluntary disclosures reduce the chances of huge fines and unnecessary scrutiny.