Office of Research Compliance and Assurance

Export Control

Sponsored Projects

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 College of Medicine 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 ExportControls. 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.

Standard Operating Procedures:

Oversight of Export Controls and Sponsored Projects (pdf file)

Resources:

Pre-award checklist (pdf file)
Post-award checklist (pdf file)
Export Control Review Flowchart for Proposals (pdf file)

NEWS FLASH!

December 20, 2007: Commerce Secretary Receives Report and Recommendations from Deemed Export Advisory Committee; Commerce Department to Review Findings
Read More

December 2007: Recent Major Enforcement Cases Reported by the Commerce Department's Bureau of Industry and Security (BIS)
Read More

DOES YOUR RESEARCH PROJECT INVOLVE:

Shipping equipment to a foreign country?
Collaborating with foreign colleagues in foreign countries?
Training foreign nationals in using equipment?
Working with a country subject to a U.S. boycott?
Is the RFP marked "Export Controlled"?
Is the sponsor requiring pre-approval rights over publications or the participation of foreign national students?

IF SO: A determination must be made by USA as to possible license requirements. Contact Dusty Layton in the Office of Research Compliance
(460-6625 or dlayton@usouthal.edu).