Resources for SRAs - EC
What SRAs Need to Know
The Front Lines
A research administrator is in a unique position to view all facets of a research project from proposal to funding and can serve to identify possible export control issues at the earliest possible stage.
Research administrators need to be aware of potential export control issues in order to recognize and bring them to the attention of the Export Control Officer.
This process involves a cooperative effort between the Office of Export Controls,
the Sponsored Research and Sponsored Research Administrators. The role of each is
integral to conducting a thorough review of research beginning at proposal stage through
the life of the project (funding and contract provisions) to determine whether and
how a particular research project is affected by export control regulations
Why Review at the Proposal Stage?
Early review gives the PI and the university a "heads up" that the project is a high risk for export control issues before foreign nationals are hired for the project. Proposal and RFP review allows the Office of Export Controls to highlight potential export control issues such as:
- Foreign national restrictions
- Sponsor publication restrictions
- Shipping equipment outside the U.S.
- Buying equipment that is export controlled
- Use of proprietary or sensitive information
- Encryption and the use of encrypted software
- Export control language in the RFP
- Advanced work with technology for military applications
Questions to Consider when Evaluating a Research Project
The basic questions to ask include:
- What items or technologies are being used?
- Where are any items or technologies going?
- Who will access the research, items or technologies?
- What is the end use or application?
Export Control Red Flags (proposal stage):
- Export control language
- References to DoD or other high risk sponsors
- References to prohibited countries
- Sponsor is a foreign entity
- Clear military component to research
- References to "classified" information
- The research requires travel to foreign countries
- A member of the research team is a foreign national
- The research involves technology with a strong potential dual-use (civilian, commercial and military) application
Export Control in the Contract
Export Control Red Flags (contract stage)
- Publications restrictions, including approvals
- Foreign National restrictions
- Requirements for security plans
- Statement that proprietary or export controlled information will be provided
- Non-disclosure agreements are included
- Requires delivery of a prototype
- Requires foreign travel or shipment of research results
High Risk Sponsors
- Department of Defense, including all agencies, labs, and branches of the armed services;
- Department of Energy;
- Department of Homeland Security;
- National Aeronautics and Space Administration (NASA)
- Intelligence Agencies
- Corporate Sponsors including Defense Contractors
- Foreign Corporate and Government Sponsors
High Risk Areas of Research
- Materials Technology
- Remote Sensing, Imaging and Reconnaissance
- Navigation, Avionics and Flight Control
- Propulsion System and Unmanned Air Vehicle Subsystems
- Sensors and Sensor Technology
- Information Security/Encryption
- Marine Technology