Export Controls

Federal rules and regulations require Western Michigan University to assure that information, technology, software, hardware, and equipment is not released to foreign persons. The Research Export Control Policy sets forth the means by which the University complies with applicable rules and regulations. The Research Export Control Policy further stipulates the duties and responsibilities for the development, implementation, and oversight to ensure the compliance.

Export Controls applies to all personnel (employees, faculty, students, research staff, contractors, visitors, and collaborators) engaged in research, projects, activities, compensating foreign persons or international travel conducted under the auspices of Western Michigan University whether the activities are conducted on or off campus.

Committee oversight: WMU Office of Research and Innovation

WMU policies

• Research Export Control Policy
• WMU Policy for Inviting International Visitors to WMU

WMU procedures

 Procedures are currently under review. Please contact the Export Control Officer for assistance.

Examples of export control

Export controls are frequently, but not exclusively, associated with items, information or software within the following general areas:

• Advanced computer/microelectronic technology
• Chemical, biotechnology and biomedical engineering
• Navigation, avionics and flight control
• Nuclear technology

Methods of disclosure include, but are not limited to, the following:

• Access to sensitive laboratories
• Computer data disclosure
• Email communications
• Face-to-face discussions
• Phone discussions
• Fax communications
• Social media
• Tours which involve visual inspection
• Training sessions

Export control forms

• International Visitor Registration Form

• 17-1  Export Control Worksheet:  International Visitor to Western Michigan University

• 17-2  Export Control Worksheet:  International Visitor Host

• 17-2a  Export Control Worksheet:  International Visitor Host Additional Visitors

• 17-3  Export Control Worksheet:  International Collaboration

• 17-3a  Export Control Worksheet:  International Collaboration Additional Collaborators

• 17-4  Export Control Worksheet:  International Travel for Western Michigan University Activities

• 17-5  Export Control Worksheet:  Technology Control Plan

• 17-5a  Export Control Worksheet:  Technology Control Plan Access

• 17-5b Export Control Worksheet: Technology Control Plan – Collaborator 

• 17-5c  Export Control Worksheet:  Technology Control Plan – Foreign Hire No Research

• 17-5d  Export Control Worksheet:  Technology Control Plan – Foreign Hire with Research Activities

Regulation links

• Department of State—International Traffic in Arms Regulations—ITAR
• Department of Commerce—Bureau of Industry and Security’s Export Administration Regulations—EAR
• Department of Treasury—Office of Foreign Assets Control
  • Sanctions Programs and Country Information
  • Specially Designated Nationals And Blocked Persons List (SDN) Human Readable Lists

Violation—A case study

Violation of export control laws is a criminal matter that may include jail time and substantial fines. It is important to note that violations can be assigned to the individual and not just begin and end with the university, as is demonstrated in the case study here.

• Retired University of Tennessee Professor Convicted of Arms Export Violations
• Retired University Professor sentenced to four years in prison for Arms Export Violations involving citizen of China

PSA from Homeland Security

• Presentation from Homeland Security with definitions and explanations

Submit a concern

To submit a concern, use the WMU Reporting Hotline. Choose “Make a Report” at the top of the page.

Contact

Jim Center
(269) 387-5933
Export Control Officer