BIS Announces University Export Control Outreach Plan
The Bureau of Industry and Security this week announced a new initiative to improve the agency’s outreach to universities. The plan, outlined in a June 28 memo to export enforcement officials, is aimed at prioritizing outreach at universities that have an “elevated risk profile” and bolstering export control training at those schools. BIS also plans to assign dedicated agents to certain schools and conduct more “background briefings” with researchers on national security and technology risks.
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The initiative was announced two weeks after the Government Accountability Office said BIS can better tailor its outreach efforts to universities to mitigate export control risks in academia (see 2206170037). GAO said BIS field agents are often left to rely on “limited information to determine outreach priorities” when determining which schools to visit for export control “awareness” training.
Under its new initiative, BIS will now prioritize outreach at universities that have ties to foreign universities on the Entity List, are involved in Defense Department-funded research or are conducting research on sensitive technologies controlled under the Export Administration Regulations.
The agency also will assign specific outreach agents to universities to develop “long-term relationships” with researchers and help stop illegal technology transfers. Those agents will meet with the research institutions in person at least once per quarter to train researchers on the EAR, operating a compliance program and vetting parties that may have ties to the Entity List. The agents may also conduct briefings on national security threats.
Although research institutions have export compliance programs, the provisions in the Export Administration Regulations related to fundamental research are among the “most complex,” Matthew Axelrod, BIS’s top export enforcement official, said in the memo. He also said compliance in a university setting has “significant differences” than compliance in a corporate setting.
Many companies focus on a “narrow range” of controlled products, but universities work across the science, technology, engineering and math (STEM) spectrum, Axelrod said. “University export compliance officers, therefore, have the challenging task of understanding all of the research and development projects conducted on their campuses well enough to determine the export control requirements specific to each of them.”