Working with foreign national collaborators, institutions, or students may fall under the purview of various federal export control laws. In general, these regulations involve military technology (including nearly all space-based research), “dual-use” technologies (including a wide range of equipment from distillers to lasers), as well as nearly any kind of financial transactions with certain embargoed countries or individuals.
These impacts are not limited to the physical export of equipment or software; “deemed exports” include dissemination of technical information to foreign persons, whether it occurs within or outside the US. This may occur in the context of presentations, emails, personal conversations, site tours, or in training of foreign national research personnel. Penalties for violations can be severe and accrue to individual investigators as well as the University, so it is important for investigators and administrators to be aware of their responsibilities.
In many cases, basic and applied research may be included under one or more of the exemptions or exclusions provided in the regulations. In some cases, it may be necessary to apply for an export license or Technical Assistance Agreement. Licenses and TAAs can take considerable time to develop, so PIs should contact the Office of Contracts and Grants as early as possible if you think these may be required.
The primary contacts for more information about export control regulations:
The empowered official for the Boulder campus:
Joseph G. Rosse, Ph.D.
Associate Vice Chancellor of Research Integrity & Compliance
Undergraduate and graduate students who are required to complete export controls training may now do so through the CITI program website.
Export control reform updates dating from July 2, 2012 to August October 4, 2013
Manhattan U.S. Attorney and FBI Assistant Director-In-Charge announce a criminal complaint against three New York based University researchers for conspiring to receive bribes from a Chinese company and a Chinese government-supported research institute.
If you’ve wondered whether export compliance is simply a matter of red tape, our colleagues at the University of Massachusetts Lowell can tell you that it’s very serious business.