Who Does What

SVSU’s Empowered Officials - Provost, Deborah Huntley, PhD; Interim Vice President of Administration and Business Affairs, Susan Crane; and the Office of Sponsored Programs are the key personnel charged with ensuring compliance with U.S. export laws and regulations. 

The President, Geroge Grant Jr., PhD, (Empowered Official - EO) has ultimate responsibility for ensuring that SVSU complies with all U.S. Government export control laws and regulations, as well as with the procedures described in this website.  The EO is responsible to the SVSU Board of Control to ensure that the export compliance program is developed and implemented in accordance with applicable U.S. laws and regulations.  The assessment and any subsequent disclosure of potential violations of U.S. export laws and regulations by SVSU and its representative is the responsibility of the EO.

The Office of Sponsored Programs is responsible for implementing/updating SVSU’s export compliance program.  These duties include

• Providing advice and guidance to SVSU programs and individuals regarding export regulations and compliance training
• Providing updates on relevant changes to these regulations including export licensing, customs, and sanction or embargo issues
• Assesses the need for export compliance training, and provides it on a periodic basis
• Maintains SVSU’s export compliance system/internal controls/necessary procedures to deter and detect violations of the Arms Export Control Act (AECA) and the EAR
• Maintain SVSU’s registration with the DDTC as a manufacturer of defense article
• Prepare import/export licenses and agreements
• Coordinates with staff regarding recordkeeping requirements for each export
• License exports of defense articles and services and coordinates terms of agreements with foreign parties when necessary
• Conduct reviews to ensure that export control procedures are properly performed; maintained by SVSU Sponsored Programs; and notify appropriate management of the results of the review and corrective actions needed. 
• If needed, prepare confirmation of follow-up and corrective actions taken as a result of the review.
• Prepares letters for travelers who are taking laptop computers or other electronic devices on business travel, including exemption certificates for any ITAR-controlled data stored on the device.

Contact Sponsored Programs should any questions arise concerning the export of technical data, commodities, or services. 

Office Staff and Contact Information

SVSU Sponsored Programs, W 314, 7400 Bay Road, University Center, MI  48710-0001

All employees are expected to be knowledgeable with regard to the export control implications of their work.  Employees who violate the policies and procedures contained within this website will be subject to disciplinary action.  Employees are required to report immediately any suspected violation of U.S. export laws and regulations.  This notification may be made to an immediate supervisor, SVSU Sponsored Programs, or the EO.

Sponsored Programs must be aware of U.S. export laws in the processing of projects with international elements.  This office is responsible for:

• Identifying export/import activities;
• Determining impending contract terminations or amendments;
• Tag all contract requirements pertaining to Foreign Military Sales (FMS) or foreign direct commercial contracts;
• Notifying the EO of any terms/conditions of any potential contract that violate U.S. anti-boycott regulations.
• Forwarding required classified export license documentation to appropriate government agencies (e.g., DSP-85 forms)

Human Resources is responsible for

• Interviewing/hiring of foreign person (either full or part-time employees, consultants, temporary placement agency workers, students, or interns.)
• HR will review job responsibilities of all foreign person employees to check for compliance with U.S. export regulations.

Purchasing Department is responsible for:

• Ensuring that international procurements are documented or properly marked when related to USML items or otherwise subject to defense-related requirements;
• Flowing down appropriate terms and conditions to domestic subcontractors, vendors, and suppliers to ensure compliance with export laws and regulations;
• Coordinates activities with freight forwarders and Customs brokers;
• Ensuring that vendors outside the U.S. are screened against appropriate watch lists.

International and Advanced Studies Office is responsible for

• Providing a written or oral briefing to all SVSU employees/students traveling overseas on behalf of SVSU, including laptop, media, and electronic data precautions;
• Maintaining records of all foreign visitors on classified programs.

Security – University Police are responsible for:

• Maintaining records of all transfers of classified documents;
• Providing (when applicable) training to assist employees in complying with the National Industrial Security Program Operating Manual (NISPOM) requirements for safeguarding classified information.

Colleges - Each SVSU College Dean is responsible for working to ensure compliance with U.S. Government export regulations.  This means that college personnel inform Sponsored Programs of work done for/with any foreign party, including contracts with domestic clients that are being worked on by foreign persons employed by SVSU or SVSU’s subcontractors.  Each college will assume the following responsibilities:

• Follow SVSU’s requirements for reporting potential visits by foreign persons to International and Advanced Studies Office;
• Discuss with SVSU Human Resources any potential foreign employees, subcontractors, consultants, etc. to ascertain whether such persons are eligible for hire (depending on nationality, work to be performed, etc.);

• Notify SVSU Purchasing as early as possible regarding proposals and new programs involving international transactions/foreign shipments;
• Discuss with SVSU Purchasing any potential export of hardware, along with potential schedules for such exports;
• Coordinate with Shipping and SVSU Purchasing when transferring technical data packages outside of the United States;
• Assist SVSU Purchasing in reviewing defense articles/technical data for compliance with license and to ensure that items are appropriately designated within the United State munitions List (USML) or Commerce Control List (CCL);
• Promptly report any payments of fees or commissions to foreign agents/consultants to SVSU Purchasing;

• Notify Sponsored Programs to discuss any proposal or marketing presentations planned for foreign parties;
• Discuss with Sponsored Programs any plans for participation in international or open domestic trade shows;
• Confirm Sponsored Program’s approval prior to transmitting or disclosing any export controlled technical data to a foreign person via any media;
• Notify Sponsored Programs prior to any disclosure of technical information to a foreign person, including technical manuals and the provision of training at the intermediate and depot maintenance levels;
• Confirm and coordinate with Sponsored Programs prior to any shipment, or hand-carry, or licensed items including technical data.