Will you be working as a part of an International Collaboration?
The document below is used to assist with the export compliance analysis. Email the completed document to firstname.lastname@example.org for review as early in the process/collaboration as possible.
Keep a copy of the completed documents for five (5) years past the last date of the visit.
Awareness of export control laws and regulations at all stages of any research project (sponsored or non-sponsored) is important. Consider the following as it relates to your research before work begins:
What are the possible export control issues that may apply to your research project? Questions to ask:
- Are there any Export Control issues that may apply to your research project?
Are there publication restrictions?
Are there foreign national restrictions?
- Does the work involve a US sanctioned/embargoed country? (view a current list)
- Is there a Non-Disclosure Agreement (NDA), Proprietary Information Agreement (PIA), or Confidentiality Agreement (CDA) ?
- Will there be a collaboration with foreign persons or entities and/or will the research be conducted in a foreign country?
- Are there biological materials and/or chemicals in the research? If yes, how do I determine if these materials/agents are export controlled? (See the Restricted Biological Agents list and/or contact the VUMC EC Office)
- Does the project involve foreign travel or physical exports (shipping) to a foreign country?
- Does the project involve the transfer of export-controlled information or items, or is there a possibility the work may become controlled? If not certain, how do I determine? (Contact the VUMC EC Office)
If any of the answers to the questions are "yes," export compliance may be an issue and will require working with the VUMC Export Control Office along with other central research administrative offices to ensure your project is export compliant.
Research - It is important to determine if the research qualifies for the Fundamental Research Exemption (FRE).
- The Export Compliance Review Flow Chart may be used as a tool in this analysis.
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 Sponsor Program contact person. Knowing this early on and collaborating with the central research administrative office, i.e., OSP or OCM, along with the VUMC EC office can save time in negotiations and avoid delays.
- Please recognize that it is important to allow ample time for contract negotiations/review.
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 VUMC EC as necessary during this analysis process or if restrictions apply to the agreement that void the FRE.
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 VUMC-EC prior to accepting the award if such restrictions apply to grants or cooperative agreements.
Foreign Collaborations - It is recommended that any known foreign entities and foreign contacts involved in the contract/agreement/grant/research, etc. should be screened for inclusion on the denied persons list (DPL): before negotiations, when there are amendments, new task orders, changes, etc. to determine if there are any restricted or denied entities/parties involved (anywhere in the transaction).
- Print or email and save a copy of the search records and keep on file for five (5) years past the last date of activity.
- If a name is found on a denied parties list, please contact VUMC EC.
You are encouraged to contact VUMC EC any time for assistance with restricted party screening (RPS) for denied persons or entities. It is also important to consider foreign travel and shipments as they relate to foreign collaborations.