Policies & Compliance

Other Conduct of Research Issues

11.3 Information and Procedures for Export Control Regulations and Restrictions

Federal export control regulations govern access to, use of, and transfers of certain scientific instruments, technologies, software and biological materials. These regulations apply to foreign nationals[1] studying, visiting, or working in the United States, as well as to the transfer of items (including biologics) outside the United States based on the nature of the item, end use, end user, and country destination.

In addition, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers regulations governing travel, academic, research, and business transactions involving sanctioned countries and blocked parties.[2] Federal agencies also restrict engagement - including, but not limited to, export transactions - with certain individuals and entities identified on various U.S. Government restricted-party lists published in the Federal Register.

As a U.S. institution of higher education engaged in significant domestic and international research activity, the University is committed to full compliance with all applicable U.S. export control and trade-sanction regulations. University policy (https://regulations.utah.edu/research/7-007.php) requires that all operations and personnel adhere to these requirements.

Failure to comply with export control regulations may result in civil and criminal penalties against the University and, in cases of willful or intentional violations, against individual employees. Potential consequences include monetary penalties, possible criminal prosecution, federal debarment, denial of export privileges, and reputational harm that may affect funding, collaborations, and enrollment.

All University personnel are expected to familiarize themselves with export control compliance requirements relevant to their responsibilities and contact the Research Security Office (“RSO”) with any questions or concerns.

[1] For export control purposes, foreign nationals are individuals who are not U.S. citizens, lawful permanent residents (“Green Card” holders), or recipients of political asylum status.

[2] In addition to the Departments of State, Commerce, and Treasury, certain agencies (e.g., NRC, NASA, NNSA, USDA) exercise supplemental export- control authority in specific circumstances.

11.3.1 Summary of How Export Compliance Requirements Affect the University's Research, Academic, and Business Operations

Export Control Compliance Overview

While the vast majority of the University’s research qualifies as “fundamental research” - that is, research to which the sponsor has not attached publication and/or citizenship restrictions - the University does conduct some federally funded export-restricted research, as well as industry-sponsored, proprietary research and testing activities that may be subject to export controls.

In parallel with these activities, the University’s international collaborative network at times requires international transfer of instruments, software, materials, and technologies. Additionally, as a global institution, the University routinely hosts foreign national students, researchers, lecturers, and temporary visitors to the United States.

Accordingly, the University must comply, when and as required, with all export authorization requirements associated with:

transferring controlled items internationally;
sharing export-controlled technology with foreign nationals in University research environments;
avoiding engagement with U.S. Government restricted or prohibited parties; and
complying with all U.S. Treasury Department economic sanctions with respect to embargoed countries and “blocked” parties.

These compliance obligations affect a broad range of University activities, including - but not limited to -

sponsored research;
procurement;
international travel;
finance/accounts payable;
international shipments and collaborations;
hosting foreign national students and visitors;
intellectual property commercialization;
international academic teaming agreements;
information technology infrastructure and services;
advancement;
Environmental Health & Safety compliance;
and distance (on-line) learning.

Given the relevance that export control compliance requirements have across so many University functions, the University has positioned its export oversight function within the Research Security Office (RSO). The RSO is responsible for training our University community on export-control compliance and for ensuring ongoing awareness of evolving federal requirements.

Foreign Influence Prevention and Research Security

In parallel with export compliance responsibilities, the RSO plays a critical role in implementing the University’s foreign influence prevention and research security program. The term foreign influence refers to actions taken by international institutions or entities to divert U.S. taxpayer-funded research or resulting intellectual property from its intended purpose. Examples include financial and logistical incentives to conduct U.S.-funded research abroad; intellectual property penetration; visa fraud, undisclosed conflicts of interest or commitment (COI/COC); and unauthorized access to computational or research resources.

In addition, National Security Presidential Memorandum 33 (NSPM-33) and extensive implementing guidance issued by federal agencies and congressional bodies have significantly increased the University’s obligations related to sponsored research data management, including standardized disclosure requirements, cybersecurity expectations, oversight of international collaborations, information sharing protocols, and enforcement consequences for noncompliance.

In this context, the RSO partners closely with a number of University units - including the Office of Research Integrity (RIO), Office of Sponsored Projects (OSP), Information Technology, Information Security Office (ISO), and the Office of General Counsel (OGC) - to coordinate the University's institutional approach to foreign influence prevention and research security.

11.3.2 United States Export Control Regulations

11.3.2.1 Introduction to Export Control Regulations

Export control laws are a complex set of federal regulations designed to protect United States (U.S.) national security; prevent the proliferation of weapons of mass destruction; further U.S. foreign policy objectives (including support for international treaties, human rights, and regional stability); and maintain U.S. economic competitiveness.

Export control regulations govern how information, technologies, and commodities can be transmitted overseas to any person (including U.S. citizens), as well as to foreign nationals (i.e., visa holders) located in the United States. In addition to controlling exports to certain countries or destinations, these regulations restrict exports to individuals, companies, and organizations that have engaged in or facilitated activities contrary to U.S. law or global security interests (e.g., chemical or biological militarization; nuclear proliferation; geopolitical destabilization; missile development; drug trafficking activities, etc.) Export control regulations also prohibit transactions with persons or entities found to have violated U.S. export control or trade sanction laws.

Three U.S. Government federal agencies exercise primary jurisdiction over export controls:

Department of Commerce
Department of State, and
Department of the Treasury.

The Department of State administers controls on defense exports through its Directorate of Defense Trade Controls (DDTC). The Department of Commerce’s Bureau of Industry Security (BIS) administers controls on commercial and so-called “dual-use” items, which are civil in design but may have military or strategic applications. The Department of the Treasury administers trade-sanction regulations through its Office of Foreign Assets Control (OFAC).

11.3.2.2 Department of Commerce Regulations (EAR)

Regulatory Authority and Scope

The Export Administration Regulations (EAR) govern the export of dual-use items, meaning items with legitimate civil applications that may also have military or other strategic uses. Items subject to the EAR are listed on the Commerce Control List (CCL) and identified by Export Control Classification Numbers (ECCNs).

Note Regarding Commercial Availability

The fact that the University may acquire an item or material commercially from a U.S. vendor does not mean that export control regulations do not apply if the item is later shipped outside the U.S. Such items may still require an export license for international shipment.

Likewise, Items sourced from international vendors become subject to U.S. export controls upon importation into the U.S. Accordingly, returning an item to an international vendor for repair may require an export license determination, even if the item originated outside the U.S.

Important EAR Definitions and Concepts

Export is defined in 15 C.F.R. § 734.13 as an actual shipment or transmission of items subject to the EAR out of the United States, as well as the release of controlled technology or software in a foreign country or to a foreign national, whether in the United States or abroad.

Deemed Export is defined in 15 C.F.R. § 734.13(a)(2) and 734.13(b). A deemed export occurs when controlled technology or source code is released to a foreign national, regardless of location. Such a release is "deemed" to be an export to the foreign national's home country or countries. For purposes of the EAR, U.S. lawful permanent residents, naturalized U.S. citizens, and individuals protected under the Immigration and Naturalization Act (8 U.S.C. § 1324b(a)(3)) are not considered foreign nationals.

Fundamental Research is research in science, engineering, or mathematics, whose results are ordinarily published and shared broadly within the research community, and for which the researchers have not accepted restrictions for proprietary or national security reasons (15 C.F.R. § 734.8(c)). The complete definition, including its application to university-based research, is found in 15 C.F.R. § 734.8. Publication approval requirements limited solely to sponsor review for removal of proprietary information do not negate the Fundamental Research Exclusion (FRE).

An FRE determination applies only to the dissemination of research data and information, not to the transfer of physical commodities, materials, prototypes, samples, or encryption items. Accordingly, a project covered by the FRE may generate publishable information outside the scope of export regulations, while simultaneously producing tangible items that would require an export license if transferred internationally.

Published information is defined in 15 C.F.R. § 734.7 as information accessible to the interested public in any form, including journals, books, print or electronic media, public websites, and any other media available for general distribution. Information submitted to journals for consideration for publication is considered published regardless of acceptance status. Published information also includes materials available in libraries, as well as issued patents and published patent applications. Information presented at conferences open to all technically qualified attendees is likewise considered published. Software is considered published when it is available for general distribution, either free of charge or at the cost of distribution; however, certain strong encryption software remains controlled regardless of general availability.

The Commerce Control List

The Commerce Control List is found at 15 C.F.R. § 774 (available at: https://www.bis.gov/regulations/ear), classifies controlled items by ECCNs, which consist of a category and product group. There are 10 categories (0-9) and five product groups (A-E) within each category.

	COMMERCE CONTROL LIST CATEGORIES
0	Nuclear and Miscellaneous Items
1	Materials, Chemicals, Microorganisms, and Toxins
2	Materials Processing
3	Electronics
4	Computers
5 (Part 1)	Telecommunications
5 (Part 2)	Information Security
6	Sensors and Lasers
7	Navigation and Avionics
8	Marine
9	Aerospace and Propulsion

	COMMERCE CONTROL LIST PRODUCT GROUPS
A	Systems, equipment and components (finished or unfinished goods)
B	Test, inspection and production equipment (manufacturing equipment)
C	Material
D	Software
E	Technology

Under the EAR, licensing requirements depend on what is being exported, the destination, the end user, and the intended end use. ECCNs list specific reasons for control, which must be reviewed in conjunction with the Commerce Country Chart to determine whether or not a license or license exception applies.

The Commerce Country Chart is also used to evaluate whether citizenships among foreign national visa holders may be restricted from accessing certain controlled technologies under deemed-export rules.

License Exceptions

The EAR provides specific license exceptions that may authorize certain exports without a license, including limited circumstances involving temporary exports of research equipment. License exceptions are subject to conditions and limitations (15 C.F.R. § 740.2) and may impose recordkeeping and notification obligations.

When more than one license exception may apply, selecting the option with the fewest restrictions and administrative requirements minimizes compliance burden. University personnel must consult the RSO to determine whether a license exception is applicable.

Commodity Classification

The Bureau of Industry and Security (BIS) encourages exporters to self-classify items using the CCL; however, the exporter remains liable for any misclassification. When classification is uncertain, exporters may request a formal classification from BIS. The Research Security Office (RSO) is available to assist with classification determinations.

Anti-Boycott Restrictions

The EAR includes anti-boycott provisions designed to counter foreign boycotts of countries allied with the United States. These provisions, codified at 15 C.F.R. §760, apply to persons in the U.S. and to U.S. persons abroad.

Prohibited activities include, but are not limited to:

refusing to do business with a boycotted country or blacklisted entity;
discriminating based on race, religion, sex, national origin, or nationality;
furnishing information about individuals' personal characteristics;
providing information about business relationships with boycotted countries;
providing information about membership in charitable or fraternal organizations; and
implementing letters of credit containing boycott conditions.

Exceptions are limited. Requests to engage in the prohibited boycott-related activities must be reported to BIS. If boycott language is encountered in a University transaction, contact the RSO for guidance on applicability and reporting obligations.

11.3.2.3 Department of State Regulations (ITAR)

Regulatory Authority and Scope

The International Traffic in Arms Regulations (ITAR) contains the United States Munitions List (USML), which includes defense articles, related technical data, and defense services that are controlled for export purposes. ITAR 120.31 defines a defense article. In general, defense articles are items specifically designed and/or modified for defense purposes that lack a commercial (civil) equivalent. However, an article may meet the definition of a defense article even if it was not originally intended for defense purposes, provided it possesses defense-related capabilities.

Unique to the ITAR is the concept of a “defense service” as a distinct category of controlled export. Defense services are defined in ITAR 120.32 and include: a) the release of ITAR-controlled technical data to a foreign national, regardless of location (see ITAR Section 120.56 for definition of “release.”); or b) the training, advising, or instructing of foreign military personnel, governments, agencies, or representatives in support of military or defense objectives, regardless of whether ITAR-controlled technical data is involved.

Accordingly, even the use of public domain information to train, instruct, or advise a foreign military function may constitute a defense service and may require prior authorization from the U.S. Department of State’s Directorate for Defense Trade Controls (DDTC).

Under the ITAR, an export includes sending or taking a defense article out of the United States; disclosing (including oral or visual disclosure) technical data to a foreign person, whether in the U.S. or abroad; or performing a defense service for or on behalf of a foreign person, whether inside or outside the U.S. Most exports of defense articles and defense services require authorization or licensing from DDTC.

Commodity Jurisdiction

DDTC is responsible for determining whether an item, technology, or service falls under the jurisdiction of the ITAR or instead is subject to the export-control jurisdiction of the U.S. Department of Commerce. While self-classification may be possible in certain circumstances, DDTC should be consulted whenever there is uncertainty as to whether an article or service is subject to the ITAR.

11.3.2.4 Department of Treasury Regulations (OFAC)

Regulatory Authority and Scope

The Office of Foreign Asset Controls (OFAC) administers and enforces U.S. economic and trade sanctions based on U.S. foreign policy and national security interests. Many OFAC sanctions are implemented pursuant to United Nations resolutions and other international mandates. Sanctions are country- and program-specific and are subject to frequent change based in response to evolving geopolitical conditions.

In addition to foreign countries and regimes, OFAC also imposes sanctions on individuals and entities, including those designated by the U.S. government as terrorists, narcotics traffickers, and other prohibited parties. The OFAC sanctions regulations are codified at 31 C.F.R. §§ 500-599, commonly referred to as the Foreign Asset Control Regulations.

OFAC sanctions broadly prohibit most transactions between a U.S. person and persons or entities located in an embargoed country (such as Iran, Cuba, Syria, or the North Crimea and Crimean Region), as well as transactions involving individuals or entities designated as Specially Designated Nationals (SDNs). These prohibitions generally include the import or export of goods and services, associated financial transactions, and other forms of business engagement with SDNs.

Countries currently subject to some degree of OFAC sanctions include, but are not limited to, the Balkans, Belarus, Burundi, Central African Republic, Cuba, the Democratic Republic of Congo, Iran, Iraq, Lebanon, Libya, Nicaragua, North Korea, Somalia, Russia, Sudan, Syria, Ukraine, Venezuela, Yemen, and Zimbabwe. Because OFAC programs can change rapidly, it is important to review sanctions status periodically.

OFAC Licensing for Country-Based Programs

Before undertaking research, academic, or business activities involving an OFAC-sanctioned country, entity, or individual, it is essential to review the specific sanctions applicable to the proposed activity. Each program identifies activities that are exempt from the embargo (e.g., personal communications, exchange of informational materials) as well as activities that may be permitted only under an OFAC license.

Activities authorized under a General License (GL) do not require prior OFAC approval; however, the terms and conditions of the GL must be carefully reviewed, and the use of the license must be properly documented. Activities that do not fall within a general license may require a Specific License from OFAC, which must be obtained and approved prior to engaging in the sanctioned activity.

All activities conducted under either general or specific licenses are subject to OFAC audit, and related records must be maintained for five (5) years following completion of the activity. If there is uncertainty as to whether OFAC regulations apply to a proposed transaction, consult the RSO before proceeding.

11.3.2.5 Additional Considerations

Records/ Record Retention

Export control and sanction regulations impose recordkeeping requirements for regulated activities. In general, records must be retained for five (5) years after the completion of the activity and made available to the appropriate regulatory authority upon request.

Records subject to retention include, but are not limited to:

export-related memoranda and notes;
correspondence (including email);
financial and payment records;
shipping and logistics documentation; and
any other information related to the export-controlled or sanctioned activities.

Penalties for Export Violations

Violation of the export control or sanction laws may result in civil and criminal penalties, including monetary fines and imprisonment. In assessing penalties, enforcement agencies - including DDTC, BIS, OFAC, and the U.S. Census Bureau - consider a variety of mitigating factors, such as:

whether the violation was disclosed voluntarily;
whether the conduct was isolated or part of a pattern;
the existence of a compliance program at the time of the violation;
corrective actions taken after discovery; and
whether the violation resulted from inadvertence, mistake of fact, or a good faith misinterpretation of the law.

Reporting Export Violations

Any actual or suspected violation of export-control or sanctions regulations identified at the University must be reported immediately to the Research Security Office (RSO), Office of General Counsel (OGC), or a member of the University's senior leadership.

If there is uncertainty as to whether a proposed activity could violate the export control or sanctions requirements, University personnel should consult the RSO, OGC, or senior leadership before engaging in the activity.

11.3.3 Export Control Procedures

The following section identifies key processes and procedures pertaining to the University’s Export Control program.

11.3.3.1 International shipments

In the course of its academic, research, and business operations, the University periodically transfers scientific instruments, materials, software, biologics, and, in certain cases, proprietary information to locations outside the United States.

University personnel must consult the Research Security Office (RSO) to determine whether proposed shipments or transfers of proprietary information are subject to export licensing requirements. Export classification - i.e., determination of whether export controls apply based on the item and destination - must be conducted for all proposed international transfers. Once an item has been classified, re-evaluation is not required unless the item, destination, end use, or other relevant facts change.

In some instances, the University may be required to obtain an End Use Certification from the recipient, attesting that the exported item will be used for civil research or other authorized purposes.

All proposed international transfers of items of non-University entities must be screened against U.S. Government restricted party and restricted entity lists. (See Restricted Party Screening in Section 11.3.3.4)

In certain cases, the University is required to file Electronic Export Information (EEI) through the Automated Export System (AES) maintained by the U.S. Census Bureau. While third-party freight forwarders may submit EEI filings on the University’s behalf, the University remains responsible for the accuracy of the filings and must retain records of EEI submissions made for its benefit.

11.3.3.2 Export Licenses and Shipment Authorizations

Based on an item’s Export Control Classification (ECCN) or United States Munitions List (USML) category, as well as the nature of the international transaction, the Research Security Office (RSO) will apply for any required export license and ensure that all applicable license conditions are satisfied.

Export licenses may take up to 60 days to obtain from BIS or DDTC, and potentially longer if the proposed activity raises significant national security concerns. Once a license is approved, the University will inform the consignee of their responsibilities as the end user, including compliance with any applicable re-export restrictions.

11.3.3.3 Deemed Exports as They Relate to Foreign Nationals at the University

When the University sponsors an employee under a temporary non-immigrant visa, it must evaluate whether the individual's position could involve access to export-controlled information or technology. Such exposure may arise, for example, from:

participation in a sponsor-restricted project;
access to proprietary sponsor or third-party technology subject to a Non-Disclosure Agreement (NDA); or
access to certain controlled or non-public cryptographic software.

In certain research-related environments - such as High Performance Computing or laboratory machine and tooling shops - non-academic personnel who support infrastructure may also have exposure to export-controlled items and technology.

The use of ITAR-controlled items may independently trigger foreign national access restrictions due to the defense capabilities associated with such items.

In connection with filing Form I-129 for certain employment-based nonimmigrant petitions, the U.S. government requires a Certification Regarding the Release of Controlled Technology or Technical Data to Foreign Persons in the United States.

The Office of General Counsel (OGC), in coordination with the RSO, works with the sponsoring University department to assess potential export control exposure associated with the proposed position and to establish the factual basis for the I-129B Export Control Certification. This assessment is conducted through completion of a Deemed Export Questionnaire and Attestation, which must be completed by the host supervisor before the University submits the Form I-129 petition to the U.S. Citizenship and Immigration Services (USCIS).

Although obtaining J-1 Exchange Visitor status does not involve filing a Form I-129 or related certification, the same underlying export control questions apply - namely, whether the foreign national visitor will have access to export-controlled technology in the proposed research environment. Accordingly, all incoming J-1 Exchange Visitors are subject to a similar Deemed Export Questionnaire and Certification, which must be completed prior to issuance of Form DS-2019.

11.3.3.4 Restricted Party Screening

Restricted Party Screening (RPS) is required to ensure that the University’s activities do not violate end-user and diversion controls or OFAC sanctions, based on the lists of prohibited parties (i.e., entities, individuals, and organizations) published in the Federal Register on an ongoing basis.

Multiple restricted party lists must be reviewed, including those maintained by the Departments of Commerce, State, and Treasury. A consolidated overview of these lists is available at: https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern.

The University licenses the Descartes Visual Compliance software tool to conduct restricted party screening.

At a minimum, the following Individuals and entities must be screened:

International vendors and service providers (including scientific instrument suppliers and related support services)
International commercialization partners
International industry partners (sponsored research and other collaborations)
Visiting international delegations to science and engineering laboratories
Industry users of Core Laboratory or Recharge Center facilities
Consignees of international shipments
J-1 Exchange Visitors prior to issuance of a Form DS-2019, and employees on University-sponsored nonimmigrant visas prior to filing a Form I-129 with USCIS
International donors
International institutions identified or flagged during COI/COC reviews
International institutions identified by faculty as sabbatical host institutions
Parties to international academic teaming and collaboration agreements (outside of OSP); international MOUs/MOAs
International Material Transfer Agreement (MTA) partners, both sending and receiving
Recipients of international disposition of surplus instruments or equipment
International entities located in foreign countries of concern associated with proposed international travel itineraries

Restricted party screening is coordinated by the Research Security Office (RSO) or by designated personnel who are trained to perform the screening function, including representatives from the Office of General Counsel (OGC), Office of Sponsored Projects (OSP), and the Technology Licensing Office (TLO).

If a potential match is identified, the University will conduct a review to determine whether the match is valid and whether the proposed activity may proceed. In many cases, exports of any item - Including EAR99 items - to restricted parties or entities would constitute an enforceable export control violation.

11.3.3.5 Sponsored Agreement Reviews

Sponsored awards (industry, federal, University as prime or subcontractor) may incorporate non-standard clauses with export control and data security requirements. In these cases, the RSO shall coordinate with OSP the timely review and resolution of such requirements. In many cases, RSO facilitation involves the following types of support:

Pre-award briefing with the PI to evaluate export and/or data security requirements
Interpreting non-standard clauses from an export control and/or data security standpoint
Assistance in contract negotiations to remove or modify requirements
Establishing Technology Control Plans and/or coordinating System Security Plans with IT prior to research commencing
Facilitating certain sponsor-required certifications pertaining to foreign national participation or foreign influence prevention
Informing laboratory management and data disposition during the course of a research program.

11.3.3.6 Biosafety Level 2 Laboratories

Biologics contained in Biosafety Level 2 (BSL-2) containment laboratories may also be subject to dual-use controls under the Export Administration Regulations (EAR). While fundamental research involving such biologics - including their genetic elements or genetically modified materials - rarely triggers deemed export controls in the absence of sponsor-mandated restrictions, researchers and BSL-2 laboratory staff should remain aware that international transfer of these materials will trigger export license requirements, separate from hazardous shipping requirements.

This requirement also applies in situations where a University researcher is aware that a domestic (U.S.) transfer by the University will result in a subsequent, known international export. In such cases, researchers and/or laboratory staff must consult with the Research Security Office (RSO) in advance of the transfer.

11.3.3.7 Training and Recordkeeping

The University strives to ensure that all employees involved in University research have access to an appropriate level of export compliance training. The University will maintain related records—including training materials and attendance documentation—for at least five (5) years.

Consistent with regulatory requirements, the University must also retain export-related records for a minimum of five (5) years from the date of the applicable export transaction.

11.3.3.8 Communication with the Research Security Office (RSO)

There are many situations in which University personnel and student researchers should seek support from the Research Security Office (RSO). These situations include, but are not limited to, the following:

A contract or other agreement that references U.S. export control regulations (beyond a general statement requiring compliance with the law) and/or federal data security requirements
A contract or agreement that restricts access or participation based on citizenship
A contract or agreement restricts foreign patent filing
A document in which the University is requested, as part of a research partnership or consortium, to comply with another institution’s Technology Control Plan (TCP) or System Security Plan (SSP)
A research project that results- despite publishable outcomes - in the creation of an export-controlled item
An activity involving temporary or permanent shipment or transfer of export-controlled items, or the shipment of non-controlled items that require Electronic Export Information (EEI) filings
Plans to petition for or support a visa application that may involve access to export-controlled items or technology
An activity involving the import of items or technology that will be re-exported to the original foreign source
Research activities involving potentially export-controlled items, such as unmanned aerial vehicles or remotely operated vehicles, that may be used outside University premises
Activities involving foreign sponsors, collaborators, subrecipients, or other international partners
International travel by University personnel or students where there is uncertainty as to whether data stored on electronic devices, hand-carried items, or baggage may be export-controlled
International transfer of intellectual property that is not in the public domain through published patents
Hosting an international visitor or delegation in University laboratory facilities
Receipt of an export-controlled item from a domestic entity under a Material Transfer Agreement (MTA) or Non-Disclosure Agreement (NDA)
An activity or transaction involving a restricted or watch-listed party, or uncertainty arising from Visual Compliance screening results
Procurement of ITAR-controlled items or acceptance of proprietary vendor information that may be export-controlled
Notification from a U.S. Government agency or sponsor regarding an export control, foreign influence, or research security issue
Any suspected or actual breach of export control regulations.

The examples above represent commonly encountered situations in which RSO involvement is appropriate. There may be other activities requiring RSO review; accordingly, University personnel are strongly encouraged to consult the RSO whenever an activity may implicate export-control or research-security concerns.

11.3.3.9 Detecting and Reporting Violations

Any employee who suspects an actual or potential violation of export-control or sanctions regulations must immediately notify the Research Security Office (RSO), the Office of General Cousel (OGC), or a member of the University’s senior leadership team.

The RSO, OGC, or senior leadership will coordinate appropriate next steps, which may include voluntary self-disclosure to the U.S. government and implementation of corrective or remedial measures, as necessary.

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