Association of University Export Control Officers (AUECO)
AUECO is an
association of senior export practitioners with export compliance responsibilities at institutions of higher learning in the United States. Kelly Hochstetler, Sr. Research Compliance Officer, serves as UAF's representative and is an active member of AUECO.
5/3/10 - AUECO submitted comments in response to the National Aeronautics and Space Administration (NASA) proposal to ammend the NASA Federal Acquisition Regulations (Federal Register Notice Vol. 75, No. 42, pp 9860-4). The proposed changes, if adopted, would impact safeguarding of controlled unclassified information and potentially place additional restrictions on university activities.
5/3/10 - AUECO submitted comments in response to the Defense Federal Acquisition Regulations System, Department of Defense, Advance Notice of Proposed Rulemaking (Federal Register Vol. 75, No. 41, pp 9563-8) regarding 48 CFR Parts 204 and 252. In part these changes, if adopted, would establish "DoD information" as a new category of controlled unclassified information, create two tiers of protection for DoD information, and require reporting of cyber intrusion activities.
4/9/10 - AUECO submitted comments on OMB Control #1615-0009 (Federal Register Vol. 75, No. 25, pp 6212-3). This was a 60-day notice of Information Collection Under Review: Form I-129, Petition for Nonimmigrant Worker. The proposed changes (draft I-129 and instructions) included the addition of a Deemed Export Acknowledgment section. This new section, if adopted as proposed, will require that UAF conduct an export review for each H1B applicant (in addition to certain other classes). If an export license is needed, it will have to be obtained prior to filing the I-129 which could significantly lengthen processing times. AUECO argued for the removal of this new section on the grounds that it was information subject to the jurisdiction of another agency (Bureau of Industry & Security, Department of Commerce). Understanding this arguement might not be successful, AUECO also proposed revised text that would reduce burden, increase clarity, and improve the quality of the information gathered.
1/25/10 - AUECO submitted comments to the Department of State on proposed changes regarding the export of ITAR-controlled technical data. AUECO argued that U.S. universities should be covered by the proposed rule that would permit U.S. Persons to travel abroad with ITAR-controlled technical data without a license under prespecified conditions.