In an attempt to further the security of the United States, the President is authorized to control the export/import of defense articles and services (22CFR 39) by U. S. persons (ITAR Part 120.15). The Smithsonian Institution must comply with these regulations.

Because of SAO's research collaborations with international colleagues and partners, all scientific/technical (non-administrative) employees must be aware of:

• what technical information and/or equipment is in their control, which may be exported/transmitted outside the U.S. or to non-U.S. persons;
• what constitutes an export relevant to the technical information, equipment and persons at issue; and
• what the current export regulations are BEFORE making any export/transmittal outside the U. S. or to a non-U. S. person.

The SAO Export Compliance Official (SAO/ECO) is assigned to the Sponsored Programs and Procurement (SPP) Department. The SAO/ECO is responsible for the day-to-day export/import operations and compliance oversight. The SAO/ECO will answer all questions, apply for the appropriate license, identify and provide for the accounting of International Traffic in Arms Regulations (ITAR) controlled items/technical data that SAO handles, and prepare all necessary Technical Assistance Agreements (TAAs) and related documents, as necessary.

When Proposal Preparation or Independent Research and Development (IR&D) funds are allocated to Principal Investigators, notification will be given to the SAO/ECO by the person making the allocation. It is then the responsibility of the Principal Investigator receiving these funds to contact the SAO/ECO to discuss what non-U.S. disclosures are contemplated. If any non-U.S. disclosures are contemplated, the SAO/ECO will, if appropriate, obtain the necessary license from either the Department of State or Department of Commerce, and will start a file to identify and account for ITAR or Commerce controlled transactions.

All new scientific/technical (non-administrative) employees will be provided with an ITAR/Export Clearance policy, outlining the requirements and responsibilities of this policy. All scientific/technical (non-administrative) employees must review and comply with this policy and the requirements identified on the Export Control Policy web site, and are encouraged to contact the SAO/ECO identified therein for all export/import compliance issues. They should also read the Frequently Asked Questions.

Updated 4/7/08