Duties and Responsibilities: |
Research Security and Export Control Program Oversight
- Promotes a culture of compliance and oversees adherence to federal regulations as well as University and sponsoring agency policies and procedures related to research security and export controls.
- Executes compliance program activities, including conducting risk assessments, developing work plans, and taking corrective action as necessary. Partners with other university assurance functions (e.g., University Compliance, Office of General Counsel, etc.) to operate efficiently.
- Serves as the University’s research security point of contact. Responds to requests for information from external parties.
- Serves as the University’s point of contact in administering the University’s export control program and its obligations, policies and procedures. Makes all export control determinations and serves as the empowered official for ITAR. Assesses whether export control licenses are required and manages the license process with applicable federal agencies.
- Executes Villanova’s Research Security and Export Controls Manual by working closely with key University representatives, faculty and staff regarding export control obligations and safeguards. Partners with other operational units to update policies and procedures to support export control compliance.
- Maintains expertise related to ITAR, EAR, OFAC regulations, NSDD-189, CUI policies, NSPM-33, CHIPS & Science Act of 2022, federal funding agency policies, and federal contracting requirements. Coordinates institutional-wide initiatives to respond appropriately to federal regulations as they apply to research security and export control requirements. Advises the University community on trends in regulation and enforcement impacting research.
- Establishes and sustains effective working relationships, builds credibility, and works collaboratively with faculty, staff and students to foster and promote international collaborations. Coordinates operational functions and builds relationships with individuals and areas across the University impacted by research security and export controls to promote a culture of ethics and compliance. Leads and/or participates in various University committees and ad-hoc working groups related to research security, export controls, and other research-related matters.
- Develops and manages restricted party screening program. Works with users of screening software and with the vendor to grant access and train users. Reviews screening matches and adjudicates matches, coordinating with academic departments, Human Resources and the Office of General Counsel as needed.
- Reviews international visiting scholar, staff and student requests (J-1, O-1, or H-1B) for export control considerations. Coordinates with the Office of International Students and Scholars, academic departments, Human Resources, and the Office of General Counsel as needed.
- Develops process to capture and review international travel requests and supports traveler compliance with funding agency requirements and export control regulation. Promotes travel hygiene by providing travelers with information about security risks and safe travel practices as requested.
- Develops processes and training for employees around tracking export controlled equipment at Villanova and international shipments. Consults with faculty, staff and students as needed to ensure compliance with U.S. sanctions, technology export concerns, and security risks.
- Reviews research proposals, grant awards, confidentiality/non-disclosure agreements, and other contracts for which research security terms and conditions or export controls may apply. Provide advice and guidance to the University’s signature authority and/or Authorized Organizational Representative and to academic units on navigating regulatory and institutional requirements.
- Supports academic units in their development and implementation of technology control plans. Partners with principal investigators and other operations units (e.g., University IT, Facilities, etc.) to develop appropriate controls. Monitors technology control plans for compliance.
- Partners with the Office of Grants & Contracts to develop, review, and monitor risk mitigation plans as required by federal funding agencies.
Research Security and Export Control Education and Training
- Serves as subject matter expert on export controls and research security.
- Develops and provides training to the community in all matters related to export control regulations, research security, and international collaborations. Proactively raises export control and research security awareness through education and training, and by partnering with other departments/personnel to develop and monitor research security training based on regulations and functions.
- Provides subject matter-specific training to principal investigators and employees based on job function, such as international shipping, international travel, and compliance with technology control plans.
- Maintains expertise related to ITAR, EAR, OFAC regulations, NSDD-189, CUI policies, NSPM-33, CHIPS & Science Act of 2022, federal funding agency policies, and federal contracting requirements and updates campus education and training initiatives accordingly.
Maintains records and reporting
- Creates, coordinates, and maintains records of technology control plans, export license applications, restricted party screening results, and other export control issues in accordance with federal regulations and University policies and procedures.
- Oversees University compliance efforts and any reporting requirements in instances of noncompliance.
- Supports research security-related reporting requirements, including development and submission of the Foreign Gifts and Contracts Report (Higher Education Act Section 117) and Foreign Financial Disclosure Reporting (CHIPS and Science Act Section 10339B).
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