Violations of Export Controls

Violations of federal export controls laws can be costly for the individual and the University.  Sanctions for violations can include monetary penalties and criminal convictions.  Further, loss of the intellectual property from an unauthorized export can have severe consequences for the U.S.  Such consequences can be economic or even affect national security.  Below is a description of the various sanctions.  Further, some case studies of how both individuals and universities have violated export control laws.  Even inadvertent violations can result in sanctions.

Sanctions

The type and amount of sanctions depends on the Federal agency involved and the specific violations. 

Violations of the Export Administration Regulations (EAR)

  • Civil Penalties:
    • At least $12,000 for each violation
    • $120,000 if the item/information involves national security
    • Up to $300,000+ for each violation
  • Criminal Penalties:
    • Individual: $50,000 up to $250,000 per violation, plus up to 20 years in prison
    • University: $50,000 up to $1,000,000 per violation
  • Additional sanctions such as denial of export privileges, loss of federal funds, seizure of goods
  • See BIS Sanctions for more information regarding sanctions.

Violations of the International Traffic in Arms Regulations (ITAR)

  • Civil Penalties: Up to $1,000,000+ for each violation
  • Criminal Penalties: Up to $1,000,000 per violation or up to 20 years in prison per violation
  • Additionally, suspension or debarment from government contracts, revocation of export privileges

Violations of Foreign Asset Control Regulations (OFAC)

  • Civil Penalties: Up to $300,000+ per violation
  • Criminal Penalties: Up to $1,000,000 or 20 years in prison (or both) for each violation
  • Additional sanctions such as denial of export privileges, seizure of goods

Case Studies

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