Resources for Departments - EC

PI Responsibilities

The PI has primary compliance responsibility regarding export control laws and regulations. The USF System Chief Export Control Officer will assist the PI in fulfilling those responsibilities.

Prior to beginning any research project that may be subject to export control laws and regulations, the Principal Investigator should notify, as early as possible, the Export Control Officer that the work planned may be subject to export controls under EAR, ITAR or OFAC. The Export Control Officer will review the proposal or statement of work and contract to determine if the technology involved is subject to export controls.

If the planned research is subject to export controls and is funded, before starting work on the research project, the investigator(s) will cooperate with the Office of Export Controls to manage the specific export control issues. Management mechanisms include, but are not limited to the following:

  • A customized Technology Control Plan (TCP) that will outline the provisions for protecting the controlled technology and technical data such as physical/information security plans and end-of-project security measures.
  • Export Control Training for all the personnel involved in the project.
  • Personnel screening against Denied Persons Lists.
  • Obtaining an export license from the appropriate federal agency, if required. Note: Licensing takes an average of six months.

During the project, it is the responsibility of the PI to inform the USF System Chief Export Control Officer of any changes to the scope of the project and additions to project personnel for reevaluation of the export control mechanisms in place. The TCP will also need to be updated accordingly.

The PI and the project personnel will ensure that the access of foreign nationals to the restricted data or technology is denied unless an export license has been obtained.

It is the PIs responsibility to report to the Export Control Officer any violations of export control laws and regulations related to his/her export controlled project.

At the completion of the project and/or when leaving/terminating university employment, the PI will ensure that the restricted technology is securely removed/stored and the restricted technical data is disposed of according to the end-of-project security measures outlined in the TCP.