Penalties

The penalties for violating the various Export Control regulations can be severe. Below is a list of civil and criminal sanctions that may be imposed on an individual as well as the university.

Export Administration Regulations (EAR)

• Criminal Penalties
  • Individual: a fine of up to $1 million or up to 20 years imprisonment, or both, for each violation;
  • University: a fine of up to $1 million for each violation.
• Civil and Administrative Penalties:
  • $250,000 per violation or twice the value of the transaction, whichever is greater;
  • The denial of export privileges; and/or
  • Exclusion from practice; and/or
  • Seizure/Forfeiture of goods.

International Traffic in Arms Regulations (ITAR)

• Criminal Penalties:
  • Individual: a fine of up to $1 million or up to 20 years imprisonment, or both, for each violation;
  • University: a fine of up to $1 million for each violation.
• Civil and Administrative Penalties:
  • Individual: a fine of up to $500,000 for each violation;
  • University: a fine of up to $500,000 for each violation.
  • The denial of export privileges; and/or
  • Seizure/Forfeiture of goods.

Office of Foreign Assets Control (OFAC)

• Criminal Penalties:
  • Individual: a fine of up to $1 million or up to 20 years imprisonment, or both, for each violation;
  • University: a fine of up to $1 million for each violation.
• Civil and Administrative Penalties:
  • Up to the greater of $250,000 or twice the transaction value.