8.7 Recordkeeping Requirements

Describes federal and university export control documentation retention requirements.

Contact

Questions about this policy can be answered by:

Steve Eisner

Director of Export Compliance and University Export Control Officer

Vice Provost and Dean of Research

(650) 724-7072

1. Record Keeping Requirements

Each of the relevant export control regulations contain specific recordkeeping requirements that must be satisfied. In addition, the university maintains its own recordkeeping requirements in order to document its commitment to, and compliance with, export control regulations generally.

Departments or programs must keep soft or hard copies of all export documentation, including Restricted Party Screens, financial records such as purchase orders and shipping documentation (commercial/pro forma invoices, packing lists, FedEx and other international freight forwarder/courier documents), in their research project files for a period of five years from the date of the export, reexport or controlled deemed export.

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