Record Keeping

Relevant export control regulations contain specific record keeping requirements that must be satisfied. In addition, UNM maintains it own record keeping requirements in order to document its commitment to, and compliance with, export control regulations.

Departments must keep copies of all export documentation, including required licenses, financial records and shipping documentation such as invoices, Shippers Export Declarations (SEDs), Automated Export System (AES) records, and any internal campus forms related to export control regulations in their research project files for a period of five years from the date of the export, re-export or controlled deemed export. In addition, any original campus forms related to export control must be provided to the UNM Export Controls office who shall also maintain a copy for a period of five years.

Record keeping requirements under the EAR are detailed under15 CFR Ch. VII, §762.2 - 762.7. Original records are required except as provided for in §762.4. These regulations also detail requirements for digital archives, and provisos for written procedures, authorized individuals, inability for records to be altered and the quality of copies. Destruction of records is allowed after five years except for records of voluntary self disclosures and records previously required by the BIS. Both require BIS approval for destruction.

Record keeping requirements under ITAR are detailed under 22 CFR §122.5 Maintenance of records by registrants and §123.26 Requirement for exceptions. Records must be retained for five years from the expiration of the ITAR license or other approval. Technical Assistance Agreements that are no longer needed must be terminated and any unused, expired, expended, suspended or revoked licenses must be returned immediately to the Department of State.

Export control files may contain controlled information and should be secured in a locked cabinet when not in use.