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Research Compliance

Export Control

The University of Alabama, through its Office for Research Compliance (ORC), assists investigators in the safeguarding of export-controlled data/information (i.e., controlled technology or technical data, and other restricted items) and in determining the appropriate export control plan regime.

The University of Alabama has previously maintained a facility security clearance at the Secret level and was capable of managing personal security clearances for employees. The University of Alabama’s facility clearance was moved to inactive status because there were no projects which needed the status for more than a year. The University is in the process of obtaining an active facility security clearance through the Defense Security Service.

Technology Control Plan

The ORC administers a Technology Control Plan (TCP) for all export-restricted projects in order to delineate the security measures necessary to prevent unauthorized disclosure of export-controlled data and ensure compliance with ITAR and EAR regulations. All investigators listed on export-controlled projects must sign a declaration confirming their adherence to the TCP before the initiation of the project. 

The TCP provides guidance on the securing of export-restricted items from use and observation by unlicensed non-U.S. citizens or other unauthorized individuals. TCP security measures are always appropriate to the classification involved. This often requires shielding project data and materials from observation by unauthorized individuals, marking of export-control information and materials, securing controlled work products (e.g., soft and hard copy data, equipment, etc.), securing controlled electronic information (e.g., database access managed via a Virtual Private Network, encryption using 128-bit Secure Sockets Layer, etc.),  or other advanced, federally approved encryption technology and guidance to prevent disclosure of information to third parties or to individuals not associated with the contract.

Principal Investigators, department heads, and deans are responsible for ensuring that employees working on export-restricted projects are appropriately instructed in the handling of classified, export-controlled, or proprietary information and that they have signed the required TCP, as applicable. When appropriate, all foreign nationals will be briefed and informed concerning those areas of export control and export licensing actions that are pertinent to their activities.

Please contact the Office for Research Compliance, if you have any questions or comments.

Cuba Travel

There are substantial restrictions on travel to Cuba from the United States for all American citizens and U.S. residents. Travel to Cuba for tourist purposes or activities remains prohibited.

In addition, the OFAC regulations stipulate that UA faculty, staff, and students traveling to Cuba under UA sponsorship should carry an appropriate authorization letter printed on University letterhead and signed by the designated representative for UA. Please see the attached Cuba Travel Procedure Flowchart which provides information on the process for approval to travel to Cuba as a representative of UA.

Please review the Cuba Travel Information Sheet when considering travel to Cuba.

Resources

Below is a listing of all resources related to Export Control: