The Office of Contracts and Grants (OCG) assists federally-funded PIs to comply with federal regulations in regards to property, travel, accounting, ARRA requirements, cost-sharing and tech transfer.

Explanation of Export Controls Questions on OCG’s Proposal Submission Review Form

Determination of Foreign Involvement in the Proposed Research

Early identification of express sponsor restrictions, and other more latent issues like foreign involvement or proprietary influence, will allow the University time to review, adapt and potentially negotiate final award language that ensures optimum participation and freedom to publish. Disclosure of possible concerns early, i.e., at proposal phase, will not delay your proposal submission, and it will facilitate more rapid acceptance of any related award.

The Office of Export Controls (OEC) can assist with assessing foreign involvement and creating mitigation measures to allow CU Boulder to accept the award. At the proposal stage, OEC would like to know the following:

  • Will funding or support for this project come from foreign sources, including foreign governments, companies, organizations, universities, individuals, etc.?
  • Will this project involve research collaboration with foreign universities, businesses, government agencies, or other institutions?
  • Will anyone participating in research activities associated with this project receive direct financial benefit from a foreign institution, company, government agency, or other foreign entity?
  • Will funding for this project come from the U.S. Department of Defense (DoD), or a private sector sponsor who has defense industry contracts?
  • Will the project develop or advance technology that is of interest to U.S. national security (see here for list of Critical and Emerging Technologies identified as contributing to national security)?

Once there is a preliminary award, OEC will work with the Office of Contracts and Grants to review and potentially revise certain language that might restrict research and create implications for export controls. In cases where the restrictions or other constraints cannot be removed, OEC will create Technology and Access Control Plans that allow CU Boulder to accept the award. Some of the areas for review at this phase will include:

  • Does the project or sponsor restrict dissemination or publication of scientific or technical data directly or through inclusion of requirements that can cause unreasonable delay?  
  • Does the project require international travel for field research, testing, or collaboration, or international shipments (including but not limited to: component testing and repair or hand-carrying instruments or computing devices for field research) specifically for this project? 
  • Are there restrictions on who can be a participant (e.g. require a clearance, restriction on foreign national participation)? 
  • Does the project result in prototype equipment or software that is identified on U.S. government lists of export controlled items?

If you have questions, please contact the CU Boulder Office of Export Controls (OEC) at  exportcontrolhelp@colorado.edu.