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A Salute To Those of us Whose Daily Work Involves Negotiating Massive and Lumbering Bureaucracies

subject line of email I just received:

"Your Responsibilities Related to Compliance with Export Control & Trade Laws & Regulations"

final line:

"It is the responsibility of all campus community members to review export control regulations and adhere to their requirements. Willful and knowing violation of these directives is a criminal offense."



  • I am finally putting in my two weeks at my job like that. Moving from an art college to a very well funded startup. Pretty excited/relieved.
  • "Dear Instructor,

    I am writing to inform you of a substantive change to the Note Taking Program at Disability Services. A student in your class is in need of notes.

    For many years, Disability Services has made a practice of utilizing student volunteer note takers in courses as our means of providing students with disabilities who require notes as an accommodation the appropriate access they need. Each semester, we reach out to faculty to find out which courses have notes provided by their instructors and we are exceedingly grateful to all of you who model universal design principles by offering your notes and class materials to the entire class. For those instructors that do not provide notes, we have offered 1 academic credit or 45 hours of community service to student volunteers in an effort to cover the University's legal obligation to comply with the ADA. Over the years, despite repeated efforts on our part to implement technology and make the system more user friendly to student note takers, we have continued to struggle to meet our requirement of 100% compliance.

    Many of our best students have little need for additional credits or community service hours. Students are seeking money and unfortunately, our office does not have the resources to offer monetary compensation. Our office handles thousands of requests for notes in hundreds of classes. We are unable to obtain enough volunteer note takers with such remuneration offers and this keeps us from meeting our compliance obligations; a legal risk to the university.

    In an effort to best serve our students and avoid this legal risk of non-compliance, Disability Services has partnered with a company, Luvo. I encourage you to check them out online at Luvo is a peer-to-peer learning platform that is designed to improve academic outcomes. They have partnered with many campuses and employ several faculty on their board, including the former University President of Kent State. Luvo has many products, but we have partnered with them to gain access to student generated original content notes and study guides exclusively. They have strict policies on plagiarism and utilize multiple safeguards (iThenticate, TurnItIn and content review teams) to ensure that intellectual property is protected. Furthermore, Luvo strictly adheres to the Digital Millennium Copyright Act (DMCA). Unlike other sites, they will not upload questionable content such as old exams, answer keys, etc. Additionally, they are currently the only company that seeks a commitment to providing notes to Disability Services departments, free of charge.

    Luvo staff monitor the website regularly to ensure note takers are posting original student generated study materials. If desired, faculty members can preview the material posted on Luvo and flag any concerns they have regarding content. In the event that a document is determined to be someone else's work, Luvo staff will immediately remove the material and reach out to the user who posted that content. The note taker will be given one warning, and a second occurrence of plagiarism will result in termination of their account and the Dean of Students will be notified as this is a violation of the Student Code of Conduct. For more information:

    If you have concerns about students using Luvo, the best practice would be to provide your accessible notes to the class as a whole (preferably on Moodle or a class site). If we are informed (preferably by you) that notes are available, we will not seek notes via Luvo. If a student in the class still elects to provide notes on Luvo, they will be far less successful if your notes are as comprehensive as possible as it will naturally reduce demand. We cannot keep students from marketing their own student generated content notes on Luvo. Students were purchasing notes from this company prior to us partnering with them."

  • YT, there are some great resources on the web for better understanding US Trade Embargoes and other export control laws. Just take the time to educate yourself.

    I will provide a series of links and excerpts below.

    The State Department's Resource on Strategic Trade Management and Export Controls
    The three major lists of export-controlled items are the Commerce Control List (CCL), the United States Munitions List (USML), and the Nuclear Regulatory Commission Controls (NRCC).

    The CCL includes the following:

    Items on Wassenaar Arrangement Dual-Use List
    * Nuclear-related dual use commodities (compiled in the Nuclear Suppliers Group's Nuclear Referral List)
    * Dual-use items on Missile Technology Control Regime List
    * CW Precursors, biological organisms and toxins, and CBW-related equipment on the Australia Group lists
    * Items controlled in furtherance of U.S. foreign policy and other objectives, including anti-terrorism, crime control, Firearms Convention, regional stability, UN sanctions, and short supply reasons
    * Unlisted items when destined for specified end-uses or end-users (catch-all controls)
    The US Department of the Treasury's Sanctions Program and Country Information
    OFAC administers a number of different sanctions programs. The sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals.

    OFAC Sanctions Programs:
    Balkans-related Sanctions
    Belarus Sanctions
    Burma Sanctions
    Central African Republic Sanctions
    Cote d'Ivoire (Ivory Coast)-Related Sanctions
    The Bureau of Industry and Security's Commerce Control List
    A key in determining whether an export license is needed from the Department of Commerce is knowing whether the item you intend to export has a specific Export Control Classification Number (ECCN). The ECCN is an alpha-numeric code, e.g., 3A001, that describes the item and indicates licensing requirements. All ECCNs are listed in the Commerce Control List (CCL) (Supplement No. 1 to Part 774 of the EAR) which is available on the Government Printing Office website. The CCL is divided into ten broad categories, and each category is further subdivided into five product groups.
    I say again, take the time to educate yourself! These regulations exist for the purpose of national security, which is a shared commitment from which we all benefit.
  • I apologize for my lazy approach to national security

  • I am on campus at Microsoft right now
  • New client. Very interesting. I've been here since Monday and will be through tomorrow.
  • BTW congrats on the new job, Thor!
  • edited September 2015
    I worked for a large government entity. The internal politics to prevent getting stuff done versus getting stuff done were astonishing. But IMO, it is the same in any private corp with the same number of employees. Test - compare number of employees in a govtco you know with like size privateco. And worked for a 100K+ privateco, considered well managed - they were just as incompetent and wasteful as a govtco.

    I heard tales about job security at this govtco. Govtco employees could literally not be fired. A story was of a govtco employee who engaged in sexual harassment. They could not be fired, so they were exiled to a remote sited solo job site, full pay, full job security.
  • edited September 2015
    You guys I need to complete my Bloodborne Pathogens training module ASAP. Not to mention Sexual Harrassment in the Workplace! HR is sending reminders with red subject lines! Load up those modules, Teach!
  • Who is Thor? Do I know Thor? Congrats, whoever-you-are, on your new job at a cool start-up!
  • Agreed, Dr W, I can't even handle working at a company with more than 50 employees because I start to feel the bullshit creeping in. Give me a nice team of 15 or less and I'm happy.
  • Thanks flossy
  • edited September 2015
    Also, word MJ. I was at a school with tons of employees + it was 100% an academic art crowd. No offense to those of you who are one of those. I generally like academic art people individually a lot, but at least at my former job, crowds of them seemed to invite a lot of people desperately trying to be know it alls in front of each other and TONS of ridiculous and mind bogglingly petty fights and grudges between management. Could have just been the place too. It is a huge relief to be out. I have never seen a lower glassdoor rating at a place I worked.
  • remember how I had to go to that "anti workplace-bullying" workshop
  • I just found the screenshot i took during my online sexual harassment training years ago. Good times.
  • I also had to take an online training that was 80% just about how much money you're allowed to spend on dinner if you are entertaining a senator or anyone who lobbies for an issue you work on
  • there was clip art of lobsters and golf clubs
  • Shrimp and White Wine with the Monsanto lobbyist
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