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Export Controls

Export Controls

West Texas A&M University must comply with the United States export control laws and regulations, including, without limitation, those implemented by the Department of Commerce through its Export Administration Regulations (EAR) and the Department of State through its International Traffic in Arms Regulations (ITAR), as well as those imposed by the Treasury Department through its Office of Foreign Assets Control (OFAC).

WTAMU has an obligation to implement an export control compliance program to reduce the risk of export control violations. All employees and students are responsible for the export control implications of their work and must ensure that their activities conform to export control laws and regulations. There are several institutional and individual sanctions for violations of export control laws and regulations, including the loss of research funding, the loss of export privileges, and criminal and civil penalties.

The export of certain items, technologies, software, and services is regulated for reasons for national security, foreign policy, prevention of the spread of weapons of mass destruction, and competitive trade. Export control laws restrict the shipment, transmission, or transfer of certain items, software, technology, and services from the United States to foreign countries. Export control laws also restrict the shipment, transmission, or transfer of 'deemed exports’ which are releases of controlled physical items or controlled information to foreign nationals located in the United States.

In general, export control regulations cover four main types of university activities:

  • Transfers of controlled information, including technical data, to persons and entities outside the United States;
  • Shipment of controlled physical items, such as scientific equipment, that require export licenses from the United States to a foreign country;
  • Verbal, written, electronic, or visual disclosures of controlled scientific and technical information related to export controlled items to foreign nationals ("deemed exports"), even when it occurs within the United States; and
  • Travel to certain sanctioned or embargoed countries for purposes of teaching or performing research.

International Travel

At West Texas A&M University, we recognize travel plays an important role in education, research, and global engagement. As international travel becomes more common, it’s essential to balance these opportunities with the safety of our students, faculty, and staff.

Please notify your department head of any planned or expected international travel. For university-related travel, the Request for Foreign Travel Form must be completed and included with the Notification of Absence. Submit all requests for foreign travel as early in the process as possible to allow sufficient time for processing. It can take up to 6-months to obtain federally-mandated permits in some cases. All requests should be submitted at least 90 days prior to the date of travel.

Due to ongoing global tensions, Texas A&M University System restricts non-essential travel to countries or regions identified as extreme risk. Before making travel plans, all members of the WTAMU community must carefully evaluate if the trip is essential to the university’s mission. TAMUS Extreme Risk Countries includes a current list of extreme risk areas. 

Additionally, under Executive Order GA-48 by the Governor of the State of Texas, all System employees who plan to travel for personal reasons to a country identified as a foreign adversary must complete a Certification of Personal Travel to a Foreign-Adversary form in Workday.

Travel to countries listed as Countries of Concern must be reviewed per the process described in WTAMU Rule 15.05.04.W1. This review takes place during the foreign travel review process. However, to expedite the review process, notify the export control office of any international travel as soon as the anticipated travel is identified.

International Collaborations

All international collaborations must be reported to the export control office for review.

General Prohibitions regarding International Collaborations/Engagements.

  • WTAMU employees are prohibited from participating in Malign Foreign Talent Recruitment Programs.
    • All solicitations must be immediately reported to your supervisor and the export control office.
  • The university is prohibited from maintaining contracts or agreements involving a Confucius Institute.
  • Employees are prohibited from accepting gifts from a Country of Concern. Report all gifts originating from foreign companies or subsidiaries to the export control office, immediately.
  • Employees are prohibited from entering into agreements or participating in collaborations (including research and publication) with entities listed pursuant to Section 1286 of the National Defense Authorization Act.
    • Notify the export control office prior to engaging in international collaborations/agreements

Suspect a Violation?

Individuals are encouraged to report the suspected violations to the Export Control Official, the Empowered Official, through the Risk, Fraud & Misconduct Hotline at 888-501-3850 or through the online portal. 

For more information, contact:
  • Richard Smith, Assistant Vice President of Research, Compliance, and Risk, Director of AREHS: (rcsmith@wtamu.edu) Phone (806) 651-2740
  • Dr. Angela Spaulding, Empowered Official (aspaulding@wtamu.edu) Phone (806) 651-2731

Resources/Training

Export Control Basic Training is required for all employees and is delivered via TrainTraq (course number 2111212). Depending on the nature of an individual’s activities and/or job functions, a University employee or researcher may be required to supplemental export control training as deemed appropriate by the individual’s supervisor and/or the ECO.