In order to maintain KU's export compliance program and ensure consistent adherence to U.S. export control laws, the Export Control Team, Office of Export Compliance (OEC), Empowered Officials, and KU Internal Audit may conduct reviews and audits of all aspects of the program, including, but not limited to, Restricted Party Screening, Technology Control Pans, Recordkeeping, and training for project teams involved in export controls. The purpose of the reviews are to identify possible violations and identify deficiencies in training, procedures, etc., for corrective action. Findings will be reported to the senior Empowered Official and other leadership as appropriate.
The Export Control Officer (ECO) will coordinate and conduct periodic reviews to ensure that the KU community understands the export control program outlined in KU's export compliance manual and that all procedures contained in the program are implemented and being monitored. The ECO will document the results of such reviews.
The University’s Office of Internal Audit will conduct a limited review of the export control program on an annual basis with a detailed review conducted every 3 to 4 years to ensure that KU is in compliance with Federal laws and regulations related to export controls. Furthermore, the Office of Internal Audit will assist the Offices of General Counsel and Export Compliance upon request, in investigations related to potential export control violations.
KU internal audits should include, but is not limited to, the following:
• Interviews with export-related personnel and management;
• Analysis of export control checks especially screening practices and internal controls for compliance;
• Comparison of operational practices to written procedures;
• Review of management commitment;
• Review of current policies and procedures including all written guidelines;
• Review of training and education programs;
• Review of the order processing system;
• Analysis of the export authorization process;
• Analysis of the implementation of export licenses including adherence to and tracking of license conditions;
• Review of internal assessments;
• Review of notifications of noncompliance;
• Review of procedures for corrective action and follow-up;
• Review of procedures related to visits or employment of foreign nationals;
• Review of technology controls and technology transfers, including via e-mails;
Review of procedural checklists for travel abroad, including for hand carried items like laptop computers;
• Review of recordkeeping practices;
• Sample review of export-related documents; and analysis of sample transactions.