Export Controls

Penalties for Export Control Violations

The Export Administration Regulations (EAR)

Criminal Sanctions:

"WILLFUL VIOLATIONS"

University - A fine of up to the greater of $1,000,000 or five times the value of the exports for each violation;

Individual - A fine of up to $250,000 or imprisonment for up to ten years, or both, for each violation.

"KNOWING VIOLATIONS"

University - A fine of up to the greater of $50,000 or five times the value of the exports for each violation;

Individual - A fine of up to the greater of $50,000 or five times the value of the exports or imprisonment for up to five years, or both, for each violation.

Civil (Administrative) Sanctions:

The imposition of a fine of up to $12,000 for each violation, except that the fine for violations involving items controlled for national security reasons is up to $120,000 for each violation.

Additionally, for each violation of the EAR any or all of the following may be imposed:

• The denial of export privileges; and/or
• The exclusion from practice; and/or
• Seizure/Forfeiture of goods.

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The International Emergency Economic Powers Act (IEEPA)

NOTE: Penalties associated with violations of the Export Administration Regulations presently fall under the purview of IEEPA, pending reauthorization of the Export Administration Act (EAA). IEEPA sanctions are as follows:

Criminal Sanctions:

University - A fine of up to $1,000,000 for each violation;

Individual - A fine of up to $1,000,000 or imprisonment for up to twenty years, or both, for each violation.

Civil (Administrative) Sanctions:

University - A fine of up to $250,000 for each violation, or twice the value of the transaction, whichever is greater;

Individual - A fine of up to $250,000 for each violation, or twice the value of the transaction, whichever is greater.

Additionally, for each violation of the IEEPA any or all of the following may be imposed:

• The denial of export privileges; and/or
• The exclusion from practice; and/or
• Seizure/Forfeiture of goods.

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The International Traffic in Arms Regulations (ITAR)

Criminal Sanctions:

University - A fine of up to $1,000,000 for each violation;

Individual - A fine of up to $1,000,000 or up to ten years in prison, or both, for each violation.

Civil Sanctions:

University - A fine of up to $500,000 for each violation;

Individual - A fine of up to $500,000 for each violation.

Additionally, for any violation of the ITAR either or both of the following may be imposed:

• The denial of export privileges; and/or
• Seizure/Forfeiture of goods.

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The Office of Foreign Assets Control (OFAC)

Criminal Sanctions:

University - A fine of up to $1,000,000 for each violation;

Individual - A fine of up to $1,000,000 or up to twenty years in prison, or both, for each violation.

Civil Sanctions:

University - A fine of up to $55,000 for each violation;

Individual - A fine of up to $55,000 for each violation.

Additionally, for any violation of the OFAC regulations, seizure and forfeiture of goods may result.

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