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Rensselaer Polytechnic Institute
Rensselaer Polytechnic Institute
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The Graduate School, Rensselaer Polytechnic Institute

Division of Finance

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Export Control Compliance Policy

The following memo was distributed to all faculty from Ivar Strand on March 9, 2016.

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To The Campus Community:

In support of a strong Export Control policy, Rensselaer has been developing a process whereby no new Funds (or supplements to existing Funds) will be authorized by Research Administration and Finance (RAF) until the Principal Investigator (PI) has successfully completed the CITI Basic Training Course for Export Control Compliance. Please review the below communication, from former General Counsel Charles Carletta back in August, which was sent to a targeted audience of researchers with current or potential funding.

"Good morning,

The records of RAF indicate you have a currently funded research project. Consistent with the obligation of the Institute to comply with the export control laws of the United States, there is a need to document the relevant training of all researchers including faculty, students, staff and others.

As many of you have heard me say repeatedly, a verifiable training and compliance program is the best way to protect the individual members of our faculty from the onerous enforcement burdens of these laws. I remind you once again that compliance with the federal export control laws is the personal responsibility of the Principal Investigator on every funded grant. To facilitate this in the least cumbersome manner, we have secured a CITI module for basic education with enhancements for those more consistently affected by the export control rules and regulations.

This CITI course can be found at:

Citi Program

If you and all others you supervise have not already done so, please register and create individual CITI account[s] that can also be used for many other Institute-wide modules. Please assume that such training is legally required and should be accomplished within the next eight [8] weeks. As is the case for all CITI training, tracking is automatic. For those applying for any new contracts or grants after today, RAF will require documentation of the successful completion of the CITI export control module by all individuals expected to be performing the research before any awards are distributed. This too includes all involved faculty, students, post-docs and others. The schedule for processing applications will not be affected; it is expected the training will be completed before award distribution.

Additional export control information including the Rensselaer Export Control Management & Compliance Plan can be found at:

Office of the General Counsel

or by calling me directly at extension 6211. Again, my Office appreciates your support in this continuing effort.

Charles F. Carletta Charles F. Carletta, J.D., Secretary of the Institute and General Counsel"

At this time, RAF is ready to fully implement this training requirement and notify our entire campus community.

Therefore, effective immediately, RAF staff will be verifying completion of this training module by the PI before establishing any new funding. Please note, it is the responsibility of the PI to ensure this training has been completed for all other employees and students on the project; RAF cannot be responsible for verifying completion for all project employees.

Please let me know if there are any questions. Michael Ginsberg, Esq., Interim General Counsel for RPI has adopted this policy previously established by Charles Carletta as outlined in the correspondence cited above.

Thank you for your cooperation,

Ivar Strand, Assistant Vice President of Research Administration and Finance, strani@rpi.edu, 518-276-2161.