Tufts University recognizes the importance of complying with all U.S. export control regulations and is committed to full compliance with these regulations.
In practice, these rules govern what research instruments, materials (including biologics), software and technology that we, as a U.S. institution, can export (i.e. transfer) out of the country by any means; and what sensitive items and technology we can share with foreign national individuals (visa holders) studying, researching, working in, or visiting our facilities. These regulations also inform what research and business partners we engage with to the extent that we must avoid U.S. government-restricted or prohibited entities (entities of concern from a national security, export control or embargoed-country perspective).
U.S. Government export authorities strictly enforce export control through substantial civil and criminal penalties and sanctions, federal debarment and revocation of export privileges. Agencies have audit authority and can mandate costly oversight protocols. In addition, because of the national security implications to export control, liability for violations can be enforced against an individual employee to whom an intentional violation is attributable, separate from our institutional liability.
1. Compliance Oversight: Tufts’ export compliance program is led by the Associate Vice Provost for Research Compliance (“AVPRC”). The AVPRC is responsible for facilitating export compliance across all export-sensitive research activities.
2. Core operational/business functions: All key functions have been identified and are receiving ongoing training to implement their respective export compliance responsibilities, as follows: