Best Practices for Export Compliance in a Research Institution

Excerpt from Council on Government Relations (COGR) Export Controls Brochure

Below are some suggested practices and procedures currently in place at various institutions. These proposed practices are primarily meant to raise awareness of export control issues, facilitate the assessment of cases, and bring the appropriate university parties together as early as possible in the process.

During the proposal submission process, add questions to internal proposal routing forms inquiring of the researcher or the departmental or laboratory administrators whether:

Any restrictions are placed on publication, disclosure, dissemination, or participation by the sponsor in Requests for Proposals (RFPs) or program announcements;

The receipt of export-controlled information is expected to be furnished by others for use in the performance of this project;

Any issues regarding export control have been mentioned by the sponsor; and/or

The export of controlled technology or items is expected (shipping/transmitting).

On the part of the research administrator staff, when reviewing a proposal submitted by a researcher, the statement of work and any draft agreement or other materials provided by the sponsor should be reviewed to see if they contain any language or terms that:

Reference U.S. export regulations;

Restrict non-U.S. entity participation based on country of origin;

Prohibit access by non-U.S. citizens to project information;

Prohibit the hiring of non-U.S. citizens

Note: Export controls are laws that are in effect even if there is no sponsor specific export control language in the RFP, grant, contract, or award document.