Exports & International Sanctions
With homeland security a major priority over the past several years, the federal government has substantially increased its scrutiny of university compliance with federal regulations controlling the export of goods, technologies and information. In response, the University of Pittsburgh recently reviewed its own policies and practices with regard to the export regulations and is in the process of developing new procedures and educational training to aid in compliance.
Exports of Purchased Goods and Services
There are several export regulations with which the University must comply including the Export Administration Regulations (EARs), the International Traffic in Arms Regulations (ITARs) and others. These regulations restrict the export of certain goods, technologies and information, and various federal departments maintain lists of items that are restricted from export, as well as specific countries that may be banned from receiving such goods from the United States.
If you are purchasing products that will be shipped to locations outside of the U.S., or are contracting for services to be performed at locations outside of the U.S., the following procedure applies:
1. Department identifies international component.
2. The department will select a supplier or service provider and complete a University of Pittsburgh requisition form either in PRISM or by paper if PRISM access is not available.
3. Notify the Purchasing Department via a Purchasing Requisition Inquiry. This inquiry should state that you have goods to be delivered or services to be provided at a location outside of the United States. Your inquiry should provide as much information as possible about the supplier or potential supplier such as name, address, tax identification number, and the type of goods and services that you are considering for purchase.
4. A Purchasing Services representative will contact you within 24 hours to provide assistance.
5. After speaking to the representative, forward all documentation to Purchasing Services, 3328 Cathedral of Learning.
6. Purchasing Services will coordinate directly with the supplier to determine their ability to ship the goods overseas directly. If the supplier does not have the ability to comply with export regulations, Purchasing Services will coordinate with the University’s import/export broker to determine whether the University may ship the goods outside the United States and identify any licenses that may be necessary.
In addition to EARs and ITARs, the U.S. Treasury Department Office of Foreign Assets Control (OFAC) maintains its own list of foreign countries, specially designated nationals and other blocked persons against which the United States has issued economic or trade sanctions. See the OFAC website for further details.
Purchasing Services regularly compares all existing University suppliers and service providers to the OFAC lists to ensure the University’s compliance. Purchasing from University-wide contracted suppliers is the fastest way to order a product or service.
A number of corporations, foundations and other grant-making organizations are beginning to require, as part of the grant terms, a certification from the University stating that it does not conduct business with any country or person on the OFAC list.
Purchasing Services, along with the Office of General Counsel, will assist you in completing all requests for certification of the University’s compliance with international economic and trade sanctions.
If you have received a request to provide certification of compliance with OFAC restrictions, please notify us via a Purchasing Requisition Inquiry.
More information on export compliance can be found at http://www.pitt.edu/~provost/memo102604.html