206 20 105

Activity
II.06. ACADEMICS, INSTRUCTION AND RESEARCH/Research
Series Name
Export Controls
Series ID
206-20-105
Description

Document actions taken to demonstrate adherence to US export controls and trade sanctions laws regulating the transfer of certain items, services, technologies and information to foreign individuals and places subject to access, dissemination, or participation restrictions, including decisions to terminate, not to export or otherwise transact, as well as reexports, transshipment, or diversions of items exported from the United States. 

These records found in all media (paper, electronic, or otherwise) must include but are not limited to: 

  • export control documents as defined in Export Administration Regulations (EAR) part 772
    • license; 
    • application for license; 
    • any and all documents submitted in accordance with the requirements of the EAR in support of, or in relation to, a license application; 
    • application for International Import Certificate; 
    • Delivery Verification Certificate or similar evidence of delivery; 
    • Electronic Export Information (EEI) on the Automated Export System (AES) presented in connection with shipments to any country; 
    • a Dock Receipt or bill of lading issued by any carrier in connection with any export subject to the EAR and any and all documents prepared and submitted by exporters and agents pursuant to the export clearance requirements of part 758 of the EAR; 
    • a U.S. exporter's report of request received for information, certification, or other action indicating a restrictive trade practice or boycott imposed by a foreign country against a country friendly to the United States, submitted to the U.S. Department of Commerce in accordance with the provisions of part 760 of the EAR; 
    • Customs Form 7512, Transportation Entry and Manifest of Goods, Subject to Customs Inspection and Permit, when used for Transportation and Exportation (T. & E.) or Immediate Exportation (I.E.); 
    • and any other document issued by a U.S. Government agency as evidence of the existence of a license for the purpose of loading onto an exporting carrier or otherwise facilitating or effecting an export from the United States or any reexport of any item requiring a license;
  • records of transactions subject to OFAC regulations, including but not limited to due diligence and screening results, documentation of internal compliance measures, and license applications and outcome of those applications;
  • records of transactions subject to ITAR regulations, including but not limited to documents filed with DDTC; records detailing the production, procurement, and sale or transfer of defense articles; records of activities facilitating the export or transfer of defense items; license applications and outcome of those applications; documentation related to the provision of assistance or training to foreign individuals or entities concerning defense articles; employee screening and training; and documentation of internal compliance measures;
  • memoranda; 
  • notes; 
  • correspondence; 
  • any contract or agreement that governs the transaction of the item;
  • invitations to bid; 
  • books of account; 
  • financial records
  • shipping documents, invoices, orders, packing slips;
  • restrictive trade practice or boycott documents and reports; 
  • notification from BIS of an application being returned without action;
  • notification by BIS of an application being denied;
  • notification by BIS of the results of a commodity classification or encryption review request conducted by BIS; 
  • other records described in 15 C.F.R. 762.2(a)(12);
  • and related documentation. 
Retention and Disposal Instructions

(a) 5 years for transactions under BIS and ITAR jurisdiction from the latest of the following times, purge: 

(1) The export from the United States of the item involved in the transaction to which the records pertain or the provision of financing, transporting or other service for or on behalf of end-users of proliferation concern as described in §§736.2(b)(7) and 744.6 of the EAR;  

(2) Any known reexport, transshipment, or diversion of such item;  

(3) Any other termination of the transaction, whether formally in writing or by any other means; or  

(4) In the case of records of pertaining to transactions involving restrictive trade practices or boycotts described in part 760 of the EAR, the date the regulated person receives the boycott-related request or requirement. 

(5) contracts, grants, or any other agreements with a foreign entity reported in senior/key personnel current and pending support document submitted to the National Science Foundation or the U.S. Department of Agriculture must be maintained for 4 years after the gift or contract agreement; the date on which the gift or contract agreement terminates; or the last day of any period that applicable state public record law requires a copy to be maintained, per Important Notice No. 149 (2025) and Secretary’s Memorandum SM 1078-014 (2025);

(b) 10 years for transactions under OFAC jurisdiction, purge. 

Exception: In the event of a subpoena, audit, legal hold, public records or similar state or federal information request, halt until further instructed any scheduled disposal activities, including purging or transferring material to University Archives.