Roles & Responsibilities
In general, as NPS employees, students, and contractors you should exercise due diligence before transferring any commodity, technology or software. Ask appropriate questions to help determine if there is an export control issue, such as:
- What is the item?
- Where is it going?
- Who will receive it?
- What will be the end use?
- What else does the end user do?
Remember, violations of U.S. export control laws and regulations carry stiff penalties. Criminal and administrative penalties can be levied, depending upon the seriousness of the violation. The penalties can be levied against individual NPS employees, students, contractors, as well as NPS itself. Investigations by themselves can result in significant disruption of employee, student, and contractor resources and work schedule delays.
NPS employees, students, and contractors
As NPS students, employees, and contractors, you will perform many roles in the day-to-day performance of your duties. You should always be aware of your responsibilities in the area of export control.
- As authors, you should follow your organizational information review and release process.
- As shippers, you should work with the NPS Shipping system and Export Control Offices.
- As overseas travelers, you should follow approved travel plans and review the information on hand-carry items.
- As speakers, you should know your audience and advise them of sensitive content.
NPS Program/Project Managers
As NPS program/project managers, you should always be aware of your additional responsibilities in the area of export control.
- In planning, you should anticipate export control questions for the work involved.
- In oversight, you should ensure employees, students, and contractors understand any potential sensitivities.
- In distribution, you should follow the NPS Shipping System and review and release processes.
- In selection, you should acquire appropriate work force personnel consistent with technology restrictions.
NPS Export Control Officer
The NPS Export Control Officer (ECO), assisted by the Deputy Export Control Officer (DECO) and Export Control Working Group (ECWG) is responsible for assessing and communicating the requirements of U.S. Export Control on NPS activities. In addition, the ECO serves as the primary point of contact (POC) on export control issues, both internally and external government agencies. The ECO is also responsible for advising NPS management on the status and effectiveness of NPS’s Export Control Program, and for providing recommendations to improve the program.
Additional responsibilities include assistance with Export Licensing with the Departments of State and Commerce, Commerce Letters of Assurance, State Letters of Exemption, and Export Control Reviews on CRADAs, and NPS developed patents.
The NPS Deputy Export Control Officer assists the NPS ECO.
The NPS Export Control Working Group (ECWG)
Members of the Export Control Working Group are responsible for assisting the NPS ECO and DECO in coordinating and integrating NPS implementation of U.S. export control laws and regulations. The Group is chaired by the NPS ECO or his/her designee, and meets as necessary.