All KU personnel involved in export, import, shipping transactions must maintain accurate, complete, and consistent records of all exports for at least five years, as required by U.S. law. Records relating to individual exports should be organized and maintained in international shipping files for quick retrieval during audits. The following records must be retained:
Licenses, including any riders, terms and conditions, narrative statements, license applications, and letters of explanation will be maintained by the Export Control Officer (ECO) and department. Shipments made under a license including all associated provisos, re-export authorization or license exceptions/exemptions are monitored by the Office of Export Compliance (OEC) and appropriate member of the Export Control Team;
Records of transactions regarding any exported items, software, or technology shipped under any license or license exception, including memorandums, contracts, invitations to bid, notes, correspondence, books of account, and financial records, will be maintained by the department for five years following the transaction. Records include:
- The full name and address of the recipient;
- A full description of each item, units of quantity and value of each item, export control classification, and the date of shipment or re-export;
- License amendments, applications for international import certificates and supporting documents, and delivery verification certificates will be maintained by the OEC;
- Automated Export System (AES) confirmations, dock receipts or bills of lading, Air Waybills, commercial invoices, packing lists, shipping documents, including printed copies of email shipments, and customs documents will be maintained by the department.
- For ITAR shipments, provide the OEC a copy of all shipping documents;
- Customer destination control certificates will be maintained by the OEC;
- All boycott related requests should be forwarded to the OEC.
- All required written assurances for foreign national employees and other parties are retained in the individual employee’s personnel file and a copy retained by the OEC.