Senior Export Controls Compliance Specialist

The person in this position will work independently to lead East Carolina University’s export compliance and import compliance-related programs. This position will have a broad understanding of the university’s organizational structure and of the responsibilities of various organizational units that may be impacted by federal export and import regulatory requirements. As a result, this position will have detailed knowledge of various activities undertaken by identified organizational units. The position also creates/maintains the strategic framework by which the university complies with, to the fullest extent possible, relevant regulations. The position will interpret complex and nuanced federal export and import compliance-related regulatory requirements. Additionally, this position will identify associated risks that exist across the university’s operations, inform the appropriate organizations, engage and collaborate with the appropriate stakeholders, design new institutional programs, implement the programs, and monitor new and existing programs.

The individual in this role will periodically provide recommended updates, if any, regarding ECU’s General Governance – Export Control Compliance regulation. The individual in this position will compose and finalize relevant initial Standard Operating Procedures (SOPs)as well as periodically update SOPs to align with ECU operational changes, with federal regulatory changes, and/or with any identified risks that must be managed. Annually, the individual must prepare the Annual Report regarding the state of ECU’s overall export and import compliance program; the report is required by ECU’s Export Control Compliance regulation. The position establishes, maintains, and reports process Key Performance Indicators (KPIs) and transactional metrics. The individual will independently analyze transactional metrics, identify and implement needed process improvements, and work toward meeting or exceeding KPI targets.

The position promotes export and import compliance awareness through various mechanisms including, but not limited to, OECC website design and content updates, representing OECC at various events (such as New Faculty Orientation, Faculty Convocation, Compliance and Ethics Week, various department meetings, various committee meetings), providing training in various settings (such as in one-on-one sessions, as part of ECU’s Responsible Conduct of Research curriculum, in group sessions) and through various methods (such as general training, tailored training, individual counseling, online curriculum delivery).

The position also manages an annual Export Controls and Customs disclosure process by soliciting disclosures from relevant employees, analyzing responses, identifying records that require further review and evaluation, counseling relevant individuals and departments, and addressing any concerns, as required. The position supports ECU’s compliance with U.S. import regulations administered by U.S. Customs and Border Protection, as well as various Partner Government Agencies. The individual routinely screens international students, travel, and agreements (i.e. MOUs), visiting scholars, foreign employees, research programs and collaborations involving foreign nationals or other export control factors, and other transactions and scenarios, as necessary.

The position analyzes and facilitates international shipments. Therefore, the individual will sometimes solicit data from primary investigators, faculty, departments, etc., in order to submit and/or facilitate various federal license and permit applications. The most likely applicable government authorities include, but are not limited to, U.S Office of Foreign Assets Control (OFAC), U.S. Department of Defense Trade Controls (DDTC), U.S. Bureau of Industry and Security (BIS), Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), Department of Agriculture (DOA) – Animal and Plant Health Inspection Service (APHIS), DEA (Drug Enforcement Agency), Environmental Protection Agency (EPA) – Toxic Substances Control Act (TSCA), Food and Drug Administration (FDA) – Center for Device Radiological Health (CDRH). The individual has to monitor applications, manage any licenses or permits received, or otherwise communicate the outcome to the affected parties. The individual may be required to facilitate the establishing of a transaction’s Customs or Export Value, may have to apply import or export valuation methodology as defined in federal regulations, or communicate that information to shipment initiators. The individual may have to submit export transaction data directly to the U.S. Bureau of the Census, and/or may have to coordinate various aspects of a shipment, and may include time-sensitive researching of unfamiliar federal requirements, communicating with ECU Materials Management, freight forwarders, U.S. Customs brokers, and/or affected departments, as well as others.

The individual provides in-person cross-training to others within ORIC in order to enable continuity of service during absences. The individual composes and maintains desk procedures that assist in maintaining a methodical execution of activities and to support cross-training efforts. The position manages various inputs, such as data from ECU’s Office of Research Administration’s sponsored program systems, travel system, graduate admissions applications, employment records, and export controls disclosure system. The position routinely leverages various software applications and tools. These include, but are not limited to, a 3rd-party cloud-based Restricted Party Screening software, MS Word, MS Excel, MS Outlook, MS PowerPoint, AdobePro, U.S. Customs and Border Protection’s Automated Commercial Environment (ACE).

The individual must think critically, interpret various regulations and analyze how they affect various scenarios. Regulations include, but are not limited to, the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), Customs Duties, and various other regulations. When applicable, the individual has to be able to accurately determine the applicable Harmonized Tariff Schedule of the United States (HTSUS)/Schedule B number (including using the Customs Rulings Online Search System (CROSS)), Commerce Control List (CCL) Export Control Classification Number (ECCN), United States Munitions List (USML) category, in order to determine appropriate federal jurisdiction and classification of commodities and technology. The individual has to take appropriate courses of action when reviewing export of goods, services, and information (including deemed exports to Foreign Persons as defined within the EAR and ITAR that may occur on ECU’s campus).

The Senior Export Controls Compliance Specialist reports to the Assistant Director of the Office of Research Integrity and Compliance. The individual sometimes is required to work with University Counsel on various related matters. Other activities, as assigned.