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Research Policy Handbook

8.7

Recordkeeping Requirements

Describes federal and university export control documentation retention requirements.

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Policy Authority

VPDoR (Office of the Vice Provost and Dean of Research)

Current Version: July 6, 2022

Original Version: September 17, 2004

1. Recordkeeping 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.

As required by law, all original shipping documents (Pro Forma or Commercial Invoices, Air Waybills, Bills of Lading, and other freight forwarding/logistics paperwork) must be kept locally for a minimum of 5 years from the date of export.  In addition, the PI, the Project Manager, or another person to whom this responsibility is delegated must submit the appropriate electronic export control form describing certain relevant details of the export, including but not limited to the item, the item's destination, and the purpose of the shipment or hand carry.

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