International Subrecipients

Export Compliance for Subawards

UMB issues subawards to collaborators worldwide. Before any subaward is signed by Sponsored Programs Administration (SPA), it undergoes an export compliance review.

How the Process Works

1. Notification to Export Compliance
   When a subaward request involves a foreign organization, SPA notifies the Export Compliance Team.
2. Screening
   The team checks the organization, its principal investigator, and administrative contacts against U.S. government of denied, debarred, and restricted parties.
3. Scope of Work Review
   The Export Compliance Team evaluates whether the subaward activities may be subject to export controls. Factors considered include:
   • Type of project: research, education, or service
   • Subrecipient country and any sanctions or embargoes
   • Project activities, such as the shipment of materials or equipment
4. Resolution of Export Concerns
   • In most cases, no issues are found, and SPA is notified.
   • If a license or other export authorization from the U.S. government is required, the team works with the UMB Principal Investigator (PI) to resolve the issue.
   • The subaward cannot be issued until the necessary license or authorization is obtained, or the concern is otherwise addressed.