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Non-Compliance Penalties

Faculty and staff must take steps to ensure they do not violate the export regulations and become personally liable for substantial civil and criminal penalties.

The consequences of violating the EAR and ITAR regulations can be severe and can result in both civil and criminal penalties for the individual and for the institution.

State Department (ITAR)

  • Criminal: up to $1,000,000 per violation, up to 10 years imprisonment
  • Civil: seizure and forfeiture of the articles and any vessel, aircraft, or vehicle involved in attempted violation, revocation of exporting privileges, fines of up to $500,000 per violation

Commerce Department (EAR)

  • Criminal: $50,000 to $1,000,000 or up to 5 times the value of the export, whichever is greater per violation (range depends on the applicable law), up to 20 years imprisonment
  • Civil: loss of export privileges, fines up to $250,000 per violation or up to twice the value of the export

Treasury Department (OFAC)

  • Criminal: up to $1,000,000 per violation, up to 10 years imprisonment
  • Civil: $55,000 to $250,000 fines (depending on applicable law) per violation

Penalties apply to each individual violation, which means that if a violation relates to more than one controlled material or item or occurs on more than one occasion, each item or incident may trigger a penalty.

If you suspect a violation has occurred, contact our office immediately via email at exportcontrols@ucmerced.edu or by phone (209) 359-8335. Additionally, you may contact the UC Systemwide Whistleblower Hotline by clicking here: Online UC Whistleblower Hotline or calling 800-403-4744 (the hotline is independently operated to ensure anonymous and confidential reporting).