Export controls come into play when certain items or technologies are exported to particular countries or are at risk of being shared with denied parties. As an institution, we must consider destinations, nationalities, and screen for restricted parties prior to traveling to, hiring from, entering into agreements with, shipping, mailing, or emailing to, discussing restricted technology with, or procuring from particular countries or entities1.
If you are working on a grant proposal that has or may have export control considerations, it is important to answer the questions in KR PD related to international research and export controls. Answering these questions gives SGR advance notice so that they may conduct a courtesy review. This review may help avoid delays in executing a project should it be awarded. Answering these questions also populates a field in KR PD so that OSP personnel setting up awards are aware of export control considerations should an award be made.
Because things change in the time between proposal and award, it is important to follow up on export control considerations that develop over time. At time of award, work with your OSP Senior Research Administrator (SRA) to complete an SGA Export Control Review checklist available from your SRA. The completed checklist will be forwarded to SGR for review. The SGR checklist is applicable when reviewing financial and non-financial agreements and solicitations. Clauses and language that might suggest the need for export control include:
- References to publication/data restrictions
- Information marked as proprietary or protected by a non-disclosure agreement
- References to controlled unclassified or classified information
- Security clauses
- Privacy or security safeguards
- Cloud computing services
- Restrictions on foreign nationals
- Explicit export control terms and conditions
To learn more about export controls in general and at CSU,
- Visit the Export Control website under Secure & Global Research
- Request export control training for your unit
- Take personalized CITI program training on export controls
- Contact Secure & Global Research
1CSU Secure & Global Research, https://www.research.colostate.edu/sgr/export-control/
Blog post by Scot Allen, Director, Secure and Global Research and Tricia Callahan, Senior Research Education and Information Officer, Office of Sponsored Programs