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EXPORT CONTROL BASICS How Export Control Impacts on Research and Education

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Title: EAR/ITAR Author: mark.gill Last modified by: Murthy, Sreekant Created Date: 4/10/2003 1:59:06 PM Document presentation format: On-screen Show (4:3) – PowerPoint PPT presentation

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Title: EXPORT CONTROL BASICS How Export Control Impacts on Research and Education


1
EXPORT CONTROL BASICS How Export Control Impacts
on Research and Education

Sreekant Murthy, Ph.D. Chief Research Compliance
Officer Rowan University
2
Overview Topics to be Covered
  • The Basics Exports, Deemed Exports, Definitions
  • The Export Control Regulatory Framework --
  • ITAR, EAR and OFAC
  • Exclusions
  • Penalties
  • Application to University Research and education.
  • Export Control for Researchers

3
What is Export Control?
  • Federal laws to protect items, technical data and
    information important to the U.S.
  • U.S. laws and their implementing regulations
    prohibit the unauthorized export of certain
    controlled ITEMS, INFORMATION OR SOFTWARE to
    foreign persons or entities in the U.S. and
    abroad.
  • These laws have been in place over 20 years.
    However, they have become more prominent since
    9/11.
  • Export control laws apply to all activities not
    just sponsored research projects

4
Export Control Regulations What do they control?
  • EC regulations control the shipment or transfer,
    by any means of controlled items, software,
    technology, or services out of US.
  • EC regulations also restricts the release of
    certain information to foreign nationals here and
    abroad. This is called deemed export.
  • EC regulations my impose severe restrictions on
    the way the our faculty and students conduct
    research, which may impede international
    collaborations in certain research areas and
    especially research collaborations with
    restricted (embargoed) countries.
  • Noncompliance results in both monetary and
    criminal penalties against the individuals as
    well as the university.
  • Noncompliance may also results in reputational
    and financial harms to the university.

5
Importance of Export Control Compliance Due
Diligence
  • Export Control Regulations have far-reaching
    implications on everyday University activities.
  • Many units (administrative, academic, research)
    of the University are affected.
  • Compliance with regulations requires a
    university-wide oversight program.
  • Non-compliance with regulations places the
    University and its personnel at risk of fines
    and/or imprisonment.

6
Governments Concern
  • Open access/publication of scientific and
    technological results may provide unwitting
    assistance to nations or terrorist groups in
    developing weapons.
  • Protecting economic interests of U.S. companies.
  • Protecting U.S. national security and foreign
    policy interests by
  • Denying our adversaries the means to advance
    their military potential
  • Implementing foreign policy objectives
  • Preventing terrorism
  • Inhibiting the proliferation of Weapons of Mass
    Destruction (nuclear, biological, chemical)
  • Fulfilling Multilateral Obligations (i.e. UN
    Sanctions, Trade Agreements)

7
What is Affected?
  • All items/technology in the U.S. except
  • Publicly available technology software.
  • Publications that are artistic or non-technical
    in nature.
  • Items/technology located outside of the U.S.
  • Items of U.S. origin wherever located.
  • Foreign made items if it exceeds certain U.S.
    content or direct product of U.S. technology

8
Regulatory Framework
  • This is a complicated network of federal agencies
    and interrelated regulations that govern exports
    collectively referred to as Export Controls.
  • International Traffic in Arms Regulations (ITAR)
    are administered by Department of State
  • Controls Defense related items.
  • Export Administration Regulations (EAR) are
    administered by Department of Commerce.
  • Controls most other items.
  • Numerous other regulatory agencies control
    exports such as Department of Treasury (money),
    DOE (Nucs), DOJ (drugs), USDA (seeds), CDC-USDA
    (Biological agents).
  • Office of Foreign Assets Controls OFAC.
  • The Department of the Treasurys Office of
    Foreign Assets Controls (OFAC) administers
    economic sanctions programs with regard to a
    number of countries, using asset blocking and
    trade restrictions to accomplish US foreign
    policy and national security goals. OFAC
    periodically updates this list.
  • (http//www.treasury.gov/about/organizational-stru
    cture/offices/Pages/Office-of-Foreign-Assets-Contr
    ol.aspx.)

9
General Provisions
  • Prohibits certain exports, reexports and other
    conduct without a license, license exception or
    determination that no license is required.
  • A license is a pre-approval to export (ITAR
    EAR).
  • Usually valid for 4 years
  • Applies to a specific item to a specific country.
  • In the end, few items covered by EAR need a
    licensehowever, they must go through process to
    make the determination and be able to defend
    decision.
  • A Technical Assistance Agreement (TAA) (ITAR) is
    an agreement for the performance of a defense
    service or the disclosure of technical data.
    Rowan University will most likely use this option
    to get foreign researchers approved. A TAA does
    not authorize unrestricted publication-only an
    approval for the listed foreign person to work on
    the specific project.

10
Challenges
  • EAR is not as simple as just looking at the
    nationality.
  • Very dependent upon the specific technologysome
    countries can receive some items.
  • Time factor in determining requirements and then
    applying for and receiving licenses-could be as
    long as 90-120 daysdepending on outside agency
    review.
  • ITAR is simpler in that it considers all foreign
    nationals equally as dangerous, however,
    specific technology is still a major
    consideration.

11
Activities Triggering Export Control Issues
  • They include the following
  • Military or Defense Articles and Services
  • High Performance Computing
  • Dual Use Technologies (technologies with both a
    military and commercial application)
  • Encryption Technology
  • Missiles Missile Technology
  • Chemical/Biological Weapons
  • Nuclear Technology
  • Select Agents Toxins (see Select Agent/Toxin
    list)
  • Space Technology Satellites
  • Medical Lasers
  • Travelling
  • With high tech equipment, confidential,
    unpublished or proprietary information or data
  • Laptops, web-enabled mobile devices and other
    personal equipment
  • Shipping or takin items overseas
  • Sponsored classified research with restricted
    access to the research by foreign nationals

12
Points to Consider
  • Export control laws apply whether or not there is
    a specific reference in the award document.
  • Applies not only to the PI and assigned
    researchers-need to consider where information is
    accessible (labs/computers) control of
    information from other foreign persons.

13
Additional Considerations
  • Technology Control Management Plans (TCP)
  • Outlines how the controlled technology will be
    handled/secured to prevent access by unapproved
    foreign persons. Will be required even if there
    are no foreign persons assigned to the project.
  • Addresses physical security of labs other work
    areas as well as security of data on computer
    networks (Information Security).

14
Discussion Items
  • Publication restrictions and impact on Graduate
    students/PIs working on project.
  • Administrative process/burden
  • TAAs and Technology Control Plans are time
    consuming to prepare.
  • Requires additional interaction between PI and
    sponsor to determine what technology is
    controlled.
  • Approval process by Federal Govt can take 8-10
    weeks.
  • Security of labs/work areas/computers network

15
Recommended Actions
  • Develop Rowans policy for dealing with export
    provisions
  • Outline responsibility of Office Research (OR)
    Administrators and PIs/Departments.
  • Put more burden on PIs and the sponsor to assist
    with identification of technology.
  • Process will involve several offices such as OR,
    PIs, Departments, Research Deans, Associate Deans
    and possibly General Counsel.
  • Post policies training materials on web site.
  • Educate OR, Research Deans and Depts. on general
    guidelines of EAR/ITAR and Rowan University
    policy.

16
Common Acronyms
  • BIS Bureau of Industry and Security
  • BIS Mission Advance U.S. national security,
    foreign policy, and economic objectives by
    ensuring an effective export control and treaty
    compliance system and promoting continued U.S.
    strategic technology leadership. Maintains denied
    persons list, boycott list, and technology
    evaluation (OTE)
  • ECCN Export control Classification Number
  • Five digit alpha numeric number for export
    control classification used in CCL
  • CCL Commerce Control List
  • List of items divided into ten broad categories
    and five product groups under each of the broad
    categories.
  • ITAR International Traffic in Arms Regulation
  • EAR - Export Administration Regulations
  • OFAC Office of Foreign Assets Control
  • TAA -Technical Assistance Agreement (ITAR)
  • TCP Technology Control Plan
  • A technology control plan (TCP) stipulates how a
    company will control its technology. The plan
    establishes procedures to protect classified,
    proprietary, and export-controlled information
    to control access by foreign visitors and to
    control access by employees who are non-U.S.
    persons.
  • TTCP Technology Transfer Control Plan
  • USML- United States Munition List

17
US Munition List
  • The United States Munitions List (USML) is a list
    of articles, services, and related technology
    designated as defense- and space-related by the
    United States federal government. This
    designation is pursuant to sections 38 and 47(7)
    of the Arms Export Control Act (22 U.S.C. 2778
    and 2794(7)). These articles fall under the
    export and temporary import jurisdiction of the
    Department of State.
  • There are 20 categories of articles on the USML.

18
U.S. Munitions List (Part 121)
  • Categories
  • I- Firearms, Close Assault Weapons, Combat
    Shotguns
  • II- Guns Armament
  • III- Ammunition/Ordnance
  • IV- Launch Vehicles, Guided Missiles, Ballistic
    Missiles, Rockets, Torpedoes, Bombs and Mines
  • V- Explosives and Energetic Materials,
    Propellants, Incendiary Agents and Their
    Constituents
  • VI- Vessels of War and Special Naval Equipment
  • VII- Tanks and Military Vehicles
  • VIII- Aircraft and Associated Equipment
  • IX- Military Training Equipment

19
U.S. Munitions List (Part 121)
  • X. Personnel Protective Equipment
  • XI. Military Electronics
  • XII. Fire Control, Range Finder, Optical and
    Guidance and Control
  • Equipment
  • XIII. Auxiliary Military Equipment
  • XIV. Toxicological Agents, Including Chemical
    Agents, Biological Agents, and Associated
    Equipment
  • XV. Spacecraft Systems and Associated Equipment
  • XVI. Nuclear Weapons, Design and Testing Related
    Items
  • XVII. Classified Articles, Technical Data and
    Defense Services Not Otherwise Enumerated
  • XVIII. Directed Energy Weapons
  • XIX . Submersible Vessels, Oceanographic and
    Associated Equipment
  • XX- Miscellaneous

20
EAR Categories (Dual Use)
  1. Nuclear Materials, Facilities Equipment
    Miscellaneous Materials, Chemicals,
    Microorganisms and Toxins
  2. Materials Processing
  3. Electronics Design, Development and Production
  4. Computers
  5. Telecommunications Information Security
  6. Sensors and Lasers
  7. Navigation and Avionics
  8. Marine (ships vessels)
  9. Propulsion Systems, Space Vehicles and Related
    Equipment

21
Examples of EAR Controlled Technologies
  • Batteries and Fuel Cells
  • Cameras and Optics Equipment
  • Artificial Intelligence Software
  • Certain Computer Equipment
  • Items using Laser Technology
  • Certain Chemicals, Microorganisms and Toxins
  • The list depends on interplay of type of item,
    reason for export control and destination country
  • This list is large and a bit cumbersome to manage
  • There is an index that helps you navigate to the
    right place within the CCL by identifying the
    ECCN (export control classification number

22
Examples of ITAR Controlled Technologies and Items
  • Explosives
  • Rocket Systems
  • Military Training Equipment
  • Spacecraft and Satellite Equipment (even if not
    for military use)
  • Toxicological Agents and Equipment
  • Biological Agents
  • Radiological Equipment (including nuclear
    radiation detection and measurement devices)
  • Defense Services

23
EAR Embargoes
  • U.S. Embargoes
  • Cuba most stringent embargo
  • Iran comprehensive trade and investments
  • Sudan comprehensive
  • Syria general order
  • U.N. Embargoes (arms embargoes)
  • Iraq
  • Rwanda
  • Russia

24
ITAR Prohibited Countries
  • Arms Embargoes Cuba, Iran, North Korea, and
    Syria
  • Belarus, Burma, China, Eritrea, Sudan, Venezuela,
    and Vietnam
  • Denial Policy with Exceptions
  • Afghanistan, Cote d'Ivoire (Ivory Coast),
    Cyprus, Fiji, Haiti, Iraq, Lebanon, Liberia,
    Libya, Rwanda, Republic of the Congo, Somalia,
    Sri Lanka, Yemen and Zimbabwe.

25
Export Control Exclusions
  • Includes the following
  • Fundamental Research (ITAR and EAR)
  • Educational Exemption (ITAR only)
  • Employment Exemption (ITAR Only)
  • Public Domain
  • A license is not required if one of the above
    exclusions applies.

26
Fundamental Research Exclusions and Reasons for
loss of Fundamental Research Exclusions
  • Fundamental Exclusions include
  • Basic and applied research
  • May include foreign nationals
  • There can be no restrictions on access by
    students or others
  • No restriction on publication
  • Research carried out openly
  • Results are intended to be shared broadly in the
    scientific community
  • This Allows unrestricted access to research and
    free interchange of information, recognizes the
    open campus culture and environment and Supports
    compliance with U.S. export control regulations.
    Information in the Public Domain is not
    controlled.
  • Reasons for Loss of Exclusion
  • The university accepts any contract clause that
  • Forbids the participation of foreign persons
  • Gives the sponsor a right to approve publications
    resulting from the research or Otherwise
    operates to restrict participation in research
    and/or access to and disclosure of research
    results.
  • There are side deals between the PI and the
    sponsor

27
Education Exclusion
  • The ITAR provides that information concerning
    general scientific, mathematical or engineering
    principles commonly taught in schools, colleges
    and universities, is not included in the
    definition of technical data subject to the ITAR
    120.10(a)(5).
  • Excludes technology or materials.
  • EAR excludes education information released by
    instruction in catalog courses and associated
    teaching laboratories
  • The EAR education exclusion does not extend to
    the release of information in research labs not
    associated with catalog courses.
  • You do not need a license to share information as
    part of a course.
  • You can train foreign nationals on how to use
    most otherwise - controlled equipment that is
    part of a class or class laboratory.

28
Employment Exclusions
  • No license is required to share controlled
    technical information with a foreign person who
  • is a full-time, bona fide university employee
  • has a permanent address in the US while employed
    provided that person is
  • not a national of certain countries and
  • is advised in writing not to share controlled
    information with other foreign persons.

29
Export Control How does it Affect Researchers?
  • Researchers may be affected by export controls
    if
  • They teach courses online courses
  • They perform research on campus or elsewhere.
  • They plan to travel outside the United States to
    attend conferences and make presentations.
  • They may be interacting with foreign national.
  • They may need to ship items, software or
    information internationally.
  • They need to be careful by not violating a
    sanction or embargo when they, or the institution
    make payments for purchased items, services, or
    reimburse expenses.
  • They are required to fully comply with
    institutions EC policies and all U.S. export
    control laws and regulations.

30
Why do researchers need to know about Export
Control?
  • Researchers are at the front line of export
    control issues because
  • They have control over the scope of the research
    project
  • They are the ones who make the decision regarding
    equipment or technology which will be implemented
    and to whom it may need to be transferred
  • Because researchers have ultimate control of the
    research project, their input is critical to help
    contract administrators evaluate technical
    aspects of export control issues

31
Questions to Consider for Researchers
  • What is the technology?
  • Must know the specifics-will require help of PI
    and/or sponsor.
  • Who is going to be working on project?
  • What nationality and status?
  • Certain countries are embargoed by both agencies
    Cuba, Libya, Sudan, Iran, Iraq
  • Where is the work going to be accomplished?
  • On/off Rowan property?
  • If in Rowan University offices/labs-who has
    access?
  • Rowan has developed a checklist for researchers
    to verify whether research is EC-regulated

32
What should Faculty Know About EC?
  • International Travel
  • Shipping
  • Attending Conferences
  • Presenting in Conferences
  • Travel Restrictions
  • Deemed Export
  • Embargoed Countries list
  • Applicable Research
  • Self Checklist
  • Faculty Assistance

33
International Travel Restrictions - What
Researchers Can Take?
  • When they leave the country, everything you take
    is an export, including devices, software, and
    data.
  • They cannot take ITAR-controlled articles,
    technical data, or software (which the ITAR
    considers to be technical data) without a license
    from the State Department. Tangible items
    developed through fundamental research which was
    excluded from export controls are still subject
    to the ITAR.
  • To be clear if they have ITAR-controlled
    technical data, such as a document or drawing, on
    your laptop, you cannot take it out of the US,
    even if you have no intent to transfer the items
    to a non-US person.
  • In most cases, US and non-US persons can take
    EAR-controlled items and software, including your
    laptop and PDA, using EAR license exception TMP
    (Temporary exports) or BAG (Baggage) can use the
    exceptions to take EAR items and software.

34
International Travel Restrictions -What
Researchers Can Take (Continued)?
  • US persons can use the exceptions to take
    EAR-controlled technology, but this does not
    authorize its transfer to someone not otherwise
    authorized to receive it.
  • To be clear these exceptions dont authorize a
    non-US person to take EAR-controlled technology
    out of the US, even if it has been transferred to
    them as an acceptable deemed export
  • Continue to Using TMP (Temporary Imports, Exports
    and Re-exports) or BAG (Baggage) exceptions.
  • Remember that destination countries have their
    own import and export controls (see Travel.State.
    Gov), which may affect how researchers can use
    items while there and what you can take out of
    the destination country.

35
Attending Conferences
  • The EAR considers information released at an
    open conference, meeting, seminar, trade show,
    or other open gathering to be published, and so
    excluded from EAR control. ?
  • Open means that all technically qualified
    members of the public are eligible to attend and
    attendees are permitted to take notes or
    otherwise make a personal record (not necessarily
    a recording) of the proceedings and
    presentations.
  • An open conference can charge a registration
    fee reasonably related to cost, and can limit
    actual attendance, as long as attendees either
    are the first who have applied or are selected on
    the basis of relevant scientific or technical
    competence, experience, or responsibility.

36
Attending and Presenting at Conferences
  • The ITAR considers information released through
    unlimited distribution at a conference, meeting,
    seminar, trade show or exhibition, generally
    accessible to the public, in the United States to
    be in the public domain, and so excluded from
    ITAR control.
  • Researchers can consider information you receive
    at an open conference to be publicly available
    information, excluded from export controls.
  • Researchers can deliver or present the results of
    your fundamental research or other information in
    the EAR and ITAR scope at open conferences.
  • Outside the US, researchers can deliver or
    present the following information in the ITAR
    scope
  • General systems description ( such as top-level
    drawings, top-level narrative descriptions or
    summaries of performance requirements, key
    subsystems, top-level block diagrams, top-level
    description of operational modes, top-level
    equipment layout drawings, and top-level
    predictions of power usage or consumption), since
    this is not considered ITAR technical data (ITAR
    120.10(a)(5)).
  • Public domain information, such as published
    research results or material previously released
    in a university course, at conferences or
    meetings outside the US.

37
International Travel Restrictions on Where you
can go
  • Check the U S Department of the Treasury, Office
    of Foreign Assets Control web site for a list of
    Embargoed Countries.
  • Check the University Travel Policy.
  • If you decide to travel to an embargoed country,
    you must sign Rowans travel form before
    departure, acknowledging the risk and personal
    responsibility for the decision to travel.
  • There may be other restrictions that may need to
    be followed. Please check with Office of
    Research to obtain further information on
    International Travel.

38
International Travel Restrictions on What you can
do When you Get there
  • While US sanctions programs and restrictions on
    transactions with specific parties always apply,
    the likelihood of being affected by them
    increases when youre outside the US.
  • Cuba, Iran, North Korea, (North Sudan) and Syria
    are subject to strict controls. If you will be
    working with nationals of these countries, you
    should be familiar with both.
  • Working with China entities and nationals can be
    complicated by US policy toward China, which
    includes both enthusiastic support for commercial
    transactions and strong aversion to support of
    the Chinese military. Some apparently benign
    China institutions are considered by the US
    government to be closely related to the military,
    resulting in restrictions on transactions with
    them.
  • OFACs Specially Designated Nationals and Blocked
    Persons List and the Commerce Departments Entity
    List are the most relevant, but the government
    maintains a total of 35 lists with various
    restrictions. You can check most of these using
    the National Export Initiatives consolidated
    list, or consult Rowans Export Control Officer.

39
International Shipping
  • International shipping is also subject to
    numerous export and import controls and
    regulations. Fines, confiscation, or
    incarceration can all result from failing to
    comply.
  • Most things, and some software information, are
    export-controlled to some degree.
  • Some items are hazardous, and need to be packaged
    and labeled appropriately. Contact Rowans EHS
    for further information.
  • The shipment (Export and Import) can be delayed
    or incur unexpected costs if the paperwork is
    wrong or incomplete.
  • All imported shipments are cleared by U.S.
    Customs, with varying levels of scrutiny. Some
    items that are hazardous may be restricted.

40
Key Issues for University Research
  • Deemed Exports
  • The obligation to obtain an export license from
    BIS before releasing controlled technology to a
    foreign person is informally referred to as a
    deemed export. Release of controlled technology
    to foreign persons in the U.S. are "deemed" to be
    an export to the persons country or countries of
    nationality and is found in 734.2(b) of the EAR.
  • Scope of Fundamental Research Exclusion
  • Foreign National restrictions in contracts
  • Government-sponsored research covered by national
    security contract controls
  • ITAR defense articles and defense services,
    especially in space research and, increasingly,
    in life sciences and nanotechnology research
  • The application of OFAC sanctions to
    university-sponsored or related activities

41
Examples of common university deemed export risk
areas
  1. Equipment material purchase, usage disposal
  2. Research agreements
  3. International agreements
  4. Material transfer agreements
  5. Nondisclosure agreements
  6. Software and other intellectual property licenses
  7. International travel
  8. Select biological agents
  9. Contractual services agreements
  10. Affiliates programs

42
Examples of Applicable Research
  • Electrical engineering, integrated circuits,
    encrypted software, advanced
  • telecommunications
  • Applied physics ex. lasers and other equipment
  • Nanotechnology and new materials ex. composites
    and ceramics
  • Life Sciences and Chemicals (including academic
    medical centers and health sciences centers)
  • Optics and imaging
  • Detection of toxic chemical aerosols
  • Plasma and biomedical research with lasers
  • Research with controlled chemicals, biological
  • agents, and toxins
  • Biological samples
  • Crop dusting, aerosol dissemination
  • Tangible products of fundamental research
    (prototypes, materials, some software) are not
    excluded. These items may require authorization
    for export from the US.
  • Note The intellectual product of fundamental
    research (publishable results) is excluded from
    export controls.

43
What university areas are affected by Export
Control Regulations?
  • Engineering
  • Medicine
  • Nursing
  • Pharmacology
  • Sciences, et al.
  • Education and Training
  • Computing and Information Technology
  • Technology/Material Transfer
  • Grants and Contracts
  • General Counsel
  • International Study Programs
  • Purchasing
  • Shipping and Receiving
  • Environmental Health and Safety
  • International Collaborations

44
Questions to Ask Yourself
  • Does the research involve any of the EAR
    categories?
  • Does the research involve any item on the ITAR
    Munitions List?
  • Does the research involve technology or devices
    designed for use in military, security and
    intelligence applications?
  • Does the research involve anything else wit a
    substantial or dual-use military application?

45
Export Control Review Process
  • Assistance is available for
  • Preliminary Evaluation
  • Review proposals in the scientific areas of the
    greatest risk for export control issues
  • Red Flags
  • Encryption Software
  • Technology/Equipment on Commerce Control List
    (EAR) OR the Munitions List (ITAR)
  • Sanctioned Countries
  • Foreign Nationals/Travel
  • Proprietary Information

46
Assistance for Export Controlled Technology
  • If your technology is export controlled,
    assistance is available to Determine
  • The correct classification and reason(s) for
    control
  • If a license is required to the intended
    destination and/or recipient
  • Checking for an available license exception or
    exclusion
  • Checking the lists of restricted/debarred
    individuals and institutions denied export
    privileges and
  • Applying for a license, if necessary
  • Contact Information
  • Office of Research and Sponsored Programs
  • James Hall
  • 200 Mullica Hill Road
  • Glassboro, NJ 08028

47
Rowans Commitment for Export Control
  • Creating processes charged with monitoring export
    compliance
  • Appointing an export compliance official to
    oversee the export compliance program
  • Implementing a process for screening
    third-parties (Visual Compliance)
  • Addressing record keeping requirements
  • Establishing a procedure for employees to report
    suspected violations and
  • Providing a means for investigating potential
    violations and when necessary, reporting them to
    appropriate government agencies.

48
Consequences of Non-Compliance
  • Failure to comply with U.S. export control laws
    can result in severe penalties to individuals as
    well as the university
  • Civil penalties up to 500,000 each violation
  • Criminal penalties up to 1,000,000 each
    violation
  • Imprisonment up to 10 years.
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