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UC Comment Letters

UC Office of the President

UC Comments in Response to 2024-16496 (89 FR 60985) & 2024-22146 (89 FR 78835), End-Use and End-User Based Export Controls, Including U.S. Persons Activities Controls: Military and Intelligence End Use and End Users (July 29, 2024), RIN 0694-AJ43

Abstract

This comment letter responds to the Department of Commerce Bureau of Industry and Security (BIS)'s proposed amendments to the Export Administration Regulations originally issued on July 29, 2024. UC supports BIS’s proposed amendments to the Export Administration Regulations as a careful effort to advance national security and foreign policy goals while recognizing the need to protect academic research and collaboration. UC endorses AUECO and COGR recommendations seeking additional exclusions for routine academic activities and clearer definitions of Military-Support End Users and Intelligence End Users to avoid unnecessary disruption to international research while still safeguarding critical technologies.


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