United States Export Controls Violations and Penalties
Faculty, staff, students at OU, and the University are at risk of violating export controls regulations if the University and its community do not fully comply with all U.S. federal agencies and their explicitly stated regulations, laws, sanctions, embargoes, protocols and policies. Any violations of these compliance regulations will make the University, and affiliated individual(s) liable for intentional or unintentional actions that counteract the integrity of the United States and its national security. The University of Oklahoma and the faculty, staff, and students are not excluded from any U.S. federal penalties. These penalties can include criminal punishment and varying amounts of fines.
EAR Violation Penalties
The Export Administration Regulations (EAR) administers both criminal and civil punishments of varying degrees. For criminal prosecutions, the resulting sentence could be as high as twenty (20) years in federal prison and up to $1 million fine per resulting violation. Civil penalties for export violations can involve fines as high as $300,000 per violation. Export violations could result in the permanent suspension of export privileges for the individual and the University.
ITAR Violation Penalties
Similarly to EAR, the International Trade and Arms Regulation (ITAR) administers both criminal and civil punishments to offenders that range in severity. Criminal punishment can includes prison sentences up to 10 years and fines up to $1 million per violation. For civil penalties, the fine amount could be as much as $500,000 per export violation. Export violations could result in the permanent suspension of export privileges for the individual and the University.
OFAC Violation Penalties
The Office of Foreign Assets Control (OFAC) enforces civil charges that can be as high as $250,000 per indicted violation. Furthermore, criminal punishments from OFAC include up to twenty (20) years imprisonment.
Due to this severity of these violations, it is important to disclose any information that could be considered export controlled to the University and the Office of Export Controls in order to best comply with the stated national regulations and policies.