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Research & Shipping
Awareness of export control laws and regulations at all stages of any research project (sponsored or non-sponsored) is important. Consider the following questions as they relates to your research before you begin your work:
- Are there Export Control Issues that apply to your research project?
- Are there any publication restrictions or restrictions on foreign national participation?
- Are "troublesomeclauses" in the agreement?
- Will your research require a Non-Disclosure Agreement (NDA), Proprietary Information Agreement (PIA), or Confidentiality Agreement (CDA) ?
- Does the project involve foreign travel or sending physical exports to a foreign country?
- If the answer to any of these questions is "yes," then export compliance and export control laws are relevant to your research. Work closely with your Contract Negotiator and VEC for additional guidance to ensure compliance in your work.
What are you talking about? (Glossary)
It is important to determine if the research qualifies for the Fundamental Research Exemption (FRE). The Export Control Compliance Review Flow Chart may be used as a tool in this analysis.
All faculty should be sensitive to information found in proposal preparation documents – RFPs, RFAs, etc. – and collegial discussions suggesting that the proposed research might be export controlled. When in doubt, ask the program contact. Knowing this early on and collaborating with your Contract Negotiator can save time in negotiations and avoid delays. Please recognize that it is important to allow ample time for contract negotiations/review.
All contract negotiators should include documentation in each contract file that agreements have been evaluated for FRE applicability. A review of contracts for export controls is essential prior to the commencement of contract negotiations. Contact VEC as necessary during this analysis process or if restrictions apply to the agreement that void the FRE.
All grant managers should evaluate grant awards for the inclusion of 'non-standard' grant terms and conditions that restrict the ability to publish, the participation of foreign nationals, or restrict access to project materials or technology. Contact VEC prior to accepting the award if such restrictions apply to grants or cooperative agreements.
It is recommended that any known foreign entities and foreign contacts involved in the contract/agreement/grant/research, etc. should be screened using ListVUe™ denied persons search tool before negotiations, when there are amendments, new task orders, changes, etc. to determine if there are any denied parties involved. Print the search records and keep in the file for five years past the last date of activity. If a name is found on a denied parties list, please contact VEC.