Compliance with federal export laws is always required and ORIA will review the specific requirements for compliance and assist the investigators in understanding their rights and responsiblities. Some general guidelines are listed below:
- If the award is a grant or cooperative agreement and the work is for fundamental research (basic or applied) with no restrictions on disclosure or distribution of research results, then the award can proceed without further review.
- If the award is a contract that will employ foreign nationals and/or involve restricted technologies, then confirm with the Sponsor that an export license is not required, prior to signing the award document. Consult ORIA with questions.
- If the award document is a grant or cooperative agreement and references the export regulations, then cite the exclusion for fundamental research in the cover letter accompanying the fully executed agreement, where applicable. If the award document is a contract and references the export regulations, then confirm with the Sponsor that an export license is not required, prior to signing the award document. ORIA will need to review.
- If an award is approved for acceptance with publication restrictions, then ensure that an export license is not required prior to signing the agreement. ORIA will need to review.
- Before hiring a foreign national to work on any sponsored project, ensure that no restricted technologies are part of the project. Principal Investigators must acknowledge their responsibilities when the federal export laws apply. In particular, they must complete and sign a certification with ORIA whenever a restricted technology is the subject of their research. If no protected technologies are involved or the fundamental exclusion for basic and applied research is in effect, the PI must monitor the project and report to ORIA and the sponsor any changes in personnel or the scope of work that might affect the status of the award.