cover image: Introduction. Request for Clarity and Scope of Foreign-Security End Users (“FSEUs”).

Introduction. Request for Clarity and Scope of Foreign-Security End Users (“FSEUs”).

27 Sep 2024

The Association of University Export Control Officers (“AUECO”) respectfully submits this letter in response to Export Administration Regulations: Crime Controls and Expansion/Update of U. [...] AUECO is committed to monitoring changes in the administration of export control laws and regulations that may affect the unique nature of higher education and academia, including international academic and research collaborations. [...] The definition indicates that an organization conducting “monitoring” (among other things) is “performing the function of a ‘foreign-security end user’” and is thus an FSEU. [...] exporters to consider any organization that monitors and collects data in a D:5 country as an FSEU (e.g., an organization that monitors and collects data on pandemics and epidemiology). [...] We believe the clarifications suggested above would advance this goal by helping regulators and the regulated community direct their finite resources to end uses and end users of genuine concern while excluding relatively innocuous, low-risk activities and organizations.

Authors

Marci Copeland

Pages
3
Published in
United States of America

Table of Contents