VUMC Global Support announces updates to export compliance policy and training

By John Howser

It is the policy of Vanderbilt University Medical Center (VUMC) to comply with all applicable United States export control laws and regulations.

To comply with these changing laws, which are mandated by the U.S. Departments of State, Commerce and Treasury, Vanderbilt University Medical Center’s Office of Global Support is announcing changes to the institution’s Export Control Policy and new export compliance training modules.

Export control laws are U.S. laws that regulate the distribution of strategically important products, services, and information to foreign nationals and foreign countries for reasons of foreign policy, economic objectives and/or national security.

An export is defined as any shipment, transfer or transmission (including oral, written, electronic, or visual disclosure) of any commodity (equipment, product, material, chemical, bioagent, etc.), technology (information, technical data, assistance) or software/source code in or to one of the following:

• Outside the U.S. to anyone, including U.S. citizens abroad
• To a non-U.S. entity or individual, wherever they are located (even within the United States)

“Most people think of exports as being exclusive to physical goods, which isn’t the case. Export control laws are complex and the penalties for non-compliance can be severe, both for the individual employee and the institution. It’s really important for employees to know that our office is available to guide them through the process, regardless of how simple or complicated it may seem” said Julie Lankford, MBA, Director of Global Health Initiatives & Global Support. 

VUMC’s Export Control Policy and procedures addressing the institution’s commitment to these requirements is available now in Policy Tech.

In an effort to improve and expand institutional compliance, new Export Compliance online training modules have been developed for faculty and staff via FOTO and the Learning Exchange. Employees who are identified as requiring Export Compliance training in support of their activities at VUMC will receive instructions on how to access the modules.

Export Compliance is transitioning from PDF forms to REDCap. The PDF forms were previously utilized to capture instances of International Travel, International Shipping, Foreign Visitors, Immigration reviews (Visa deemed-exports), International Collaborations, and Restricted Party Screening requests.

REDCap surveys for all case review requests are now available on the VUMC Export Compliance website.

Each survey link can be found on the “Forms” tab on the left-hand side of the website, as well as on the respective tab corresponding to your case type – along with additional instructions and guidance.

Failure to comply with the Export Control Policy or any U.S. Export Control laws or regulations can result in civil penalties up to $250,000 per violation or criminal penalties up to $1,000,000 and/or up to 20 years in prison. Additionally, VUMC could be subject to loss of federal funding and/or be debarred or denied export privileges.