Researcher’s Obligations in Export Control
What kinds of projects raise Export Control concerns?
Any research activity may be subject to export controls if it involves the actual export or “deemed” export of any goods, technology, or related technical data that is either:
- “Dual use” (commercial in nature with possible military application); or
- Inherently military in nature
Research in the following areas can frequently require export control:
- Space sciences
- Computer Science
- Biomedical research with lasers
- Research with encrypted software
- Research with controlled chemicals, biological agents, and toxins
In addition, any of the following will raise export control questions for your project:
- Sponsor restrictions on the participation of foreign nationals in the research
- Sponsor restrictions on the publication or disclosure of the research results
- Indications from the sponsor or others that export-controlled information or technology will be furnished for use in the research
- Physical export of controlled goods or technology
Helpful Questions to Consider:
- What is the nationality of researchers INCLUDING professors and research assistants (students/postdocs)?
- Will the results be publicly available?
- Will there be restrictions on publications, access, dissemination or proprietary information?
- Will I be receiving any restricted information?
- Is the research going overseas to a foreign company, government or individual?
- What do the end-users intend to do with the research results?
How can Export Controls affect my research?
There are several scenarios that may require an export license including, but limited to:
- A physical transfer/disclosure of an item outside the U.S.
- Any transfer/disclosure of a controlled item or information within the U.S. to a foreign national or organization
- Participation of foreign national faculty, staff, or students in affected research
- Presentation/discussion of previously unpublished research at conferences or meetings where foreign national scholars may be in attendance
- Research collaborations with foreign nationals and technical exchange programs
- Transfers of research equipment abroad
- Visits to your lab by foreign national scholars (also review UTC’s policy regarding Visitors Engaged in Research
Your responsibilities as a UTC researcher
UTC researchers are expected to:
- Answer accurately the Export Controls questions in Cayuse
- Respond to follow-up questions from UTC administrators regarding Export Controls
- Work with the Office of Research Integrity to complete a Technology Control Plan when and as applicable
- Verify with the Office of Research Integrity whether export controls apply when traveling internationally to conduct research or for research-related activities (e.g., attending or reporting at conferences)
Where can I get help?
UT Points of Contact:
- Office of Research Integrity [email protected]
- David Deardorff, Interim Director of Research Integrity [email protected]
- Alexa McClellan, Assistant Director of Research Integrity [email protected]
Export Control Penalties | Export Control Links | Researcher’s Obligations in Export Control