Below are some frequently asked questions. In addition, you may find the questions and answers included in Supplement No. 1 to Part 734 - Technology and Software Subject to the EAR to be helpful.
What do I need to do if I have to ship or hand-carry UAB-owned or controlled equipment, supplies, software, biological material, or other goods to countries outside of the US?
1. Review the Export Control Decision Tree to determine if your item is on an export control list.
2. Contact the University Compliance Office if your item is on a list or if you need assistance.
3. Screen your recipient and your recipient’s organization against US export control Restricted Party Lists.
4. Document your export.
What do I need to do if I have to travel to Cuba, Iran, Syria, North Korea, Libya or Sudan on UAB business?
Immediately contact the University Compliance Office to determine if you can travel to these countries without an export license. Cuba, Iran, Syria, North Korea, Libya and Sudan are subject to US financial and trade sanctions. Travel to and transactions with these countries are tightly regulated.
What are the Export Control records retention requirements?
Export documents must be retained for a minimum period of five (5) years, calculated from one of the following points in time:
Export records under the EAR (15 CFR 762.6) must be retained for five (5) years from the latest of the following times:
- The date the export from the U.S. occurs;
- The date of any known re-export, transshipment, or diversion of such item;
- The date of any termination of the transaction, whether contractual, legal, formally in writing, or by any other means; or
- In the case of records of or pertaining to transactions involving restrictive trade practices or boycotts, the date the regulated person receives the boycott-related request.
Records relating to exports under the ITAR (22 CFR 122.5) must be maintained for five (5) years from:
- The expiration of the license or other approval to which the documentation relates;
- The date the license or other authorization is exhausted or used completely; or
- The date the license or other authorization is suspended, revoked, or no longer valid.