The penalties for non-compliance are severe. With potential fines of hundreds of thousands of dollars for each civil violation of an EAR, ITAR or OFAC regulation, the cost of not closely adhering to export laws can easily climb into the millions of dollars.

Criminal penalties for willful miss-conduct are even harsher. In these cases, not only can the university be hit with major multi-million dollar fines, but the researchers and administrators could also be sentenced to time in jail.

Export Administration Regualtions (EAR)

Criminal Sanctions for “Willful Violations”

Criminal Sanctions for “Knowing Violations”

Civil (Administrative) Sanctions:

The imposition of a fine of up to $12,000 for each violation, except that the fine for violations involving items controlled for national security reasons is up to $120,000 for each violation. Additionally, for each violation of the EAR any or all of the following may be imposed:

International Traffic in Arms Regulations (ITAR)

Criminal Sanctions:

Civil Sanctions:

Additionally, for any violation of the ITAR either or both of the following may be imposed:

Office of Foreign Assets Control (OFAC)

Criminal Sanctions:

Civil Sanctions:

Additionally, for any violation of the OFAC regulations, seizure and forfeiture of goods may result.