Summary of Procedures Involving Export Controls in Sponsored Research Proposals:
1. When completing a sponsored research proposal, Principal Investigators should seek to determine if the technologies covered by the research proposal are covered by Export Controls and indicate such on the USA Transmittal Sheet. As the individual most knowledgeable about the technologies that will be covered by a sponsored research proposal and the administrator of the technical aspects of the research, the PI is largely responsible for ensuring compliance with the requirements of the Export Control Laws in their research program at the University of South Alabama.
2. When a sponsored research proposal is received in the Office of Sponsored Programs or the Health Systems Grants Administration Office, the Administrator will review it and, if necessary complete the appropriate Export Control Review Form. Upon completion of the form, the Administrator will determine with the Office of Research Compliance and PI if the sponsored research proposal is or is not subject to Export Controls. For example, if the sponsored research proposal falls into the Fundamental Research Exception, then it is not subject to Export Controls. Alternatively, negotiation of the grant or contract may result in the removal of terms and conditions that otherwise would have subjected the sponsored research proposal to Export Controls. If not subject to Export Controls, the sponsored research proposal will be handled as usual. If subject to Export Controls, the Office of Research Compliance, in consultation with the Vice President for Research, shall take further necessary action. This may involve an application for the appropriate license, further review by outside counsel, or a determination that the sponsored research proposal should be modified or abandoned. Final decisions on the status and handling of sponsored research proposals subject to Export Controls shall rest with the VP Research.