Finance and Procurement

University personnel who support Finance and Procurement activities play a key role in export compliance and may facilitate many transactions which involve both OFAC, ITAR, and EAR regulations. FIU Procurement activities are facilitated by three main workflows and units, depending on the type of funds used in the transactions:

• Procurement activities using sponsored research funds: This type of procurement involves charges which are charged to a grant or other sponsored research activity. Procurement requests are made using an ePRAF and may be managed by sponsored research personnel.
• Vendor contracts (non-sponsored funds): This type of activity involves the establishment of a vendor contract, not primarily supported by sponsored research funds. Requests for vendor contracts are submitted by through the Finance & Administration Total Contract Manager (TCM) system. More information on the TCM system can be found on the General Counsel website or on the Finance & Administration webpage.
• Direct purchase not requiring a contract: This type of purchase involves charges made by personnel directly to an outside party, including purchases made using a pCard. Because direct purchases are not necessarily reviewed prior to completion, individuals are responsible for complying with U.S. export controls by following these guidelines when making a direct purchase:
  • For sophisticated technical equipment, hazardous materials & biologics, or restricted (not open source) software, request the Export Control Classification Number (ECCN) of the item from the vendor/ manufacturer prior to purchase. This information may be available on the vendor/ manufacturer’s website or by calling a customer service phone number. For items with an ECCN other than “EAR99”, contact the FIU Export Office for assistance.
  • For computing or telecommunications products purchased from Huawei Technologies, contact Export Control prior to purchase. The federal government is increasingly controlling purchase of Huawei-made goods, and many such purchase are prohibited by law.

To assist Finance Personnel in identifying and understanding export issues, Export Control has pulled together links to specific information, forms, and guidance documents targeted to Finance and Procurement interests. Specifically extensive information is available on our Procurement Topic page! Please do not hesitate to contact Export Control for assistance and help with questions.

Information on Specific Activities

• Receive or Use Something Controlled
• Receive a Gift from a Foreign Entity

Export Information by Topic

• Export Basics
• Export Activities
• Restricted Parties
• Embargoes and Sanctioned Countries
• Controlled Equipment, Items, and Materials
• Controlled Biologics
• Controlled Information and Software
• Jurisdiction and Classification
• Procurement
• Foreign Influence

Useful Forms

• Export Control Checklist – used for all initial awards to flag potential export control concerns
• Agreement Request Form – used for all non-monetary agreements (except MTAs)
• MTA Request Form – used for all MTA requests