Ensuring Compliance with U.S. Export Control Requirements
NSPM Directive: Export control training, as appropriate. Agencies should require that research organizations conducting R&D that is subject to export control restrictions provide training to relevant personnel on requirements and processes for reviewing foreign sponsors, collaborators, and partnerships, and for ensuring compliance with Federal export control requirements and restricted entities lists.
Under NSPM-33, federal agencies require research organizations conducting R&D subject to export control restrictions to provide training to relevant personnel. This training covers:
- Reviewing foreign sponsors, collaborators, and partnerships
- Complying with federal export control requirements
- Screening against restricted entities lists
Federal research agencies also require covered institutions to certify that individuals performing R&D involving export-controlled technologies complete appropriate training on U.S. export control and compliance requirements. Certification is satisfied when the institution provides a written or electronic attestation to the federal agency confirming that the research security program requirements have been met.
UMB Export Control Training and Support
The Office of Research & Development (ORD) provides continuous training on export control requirements for UMB administrators, faculty, and investigators. ORD’s subject matter experts, the Research Security Manager (RSM) and Export Control Officer (ECO), lead these training efforts.
- Central SPA and department administrators receive ongoing updates and training.
- Standard Operating Procedures (SOPs) and checklists are available to capture international collaborations and transactions with foreign entities.
- Training requirements for investigators and their teams are determined by the level of R&D and scope of work.
Proposal Review and Screening
ORD conducts thorough review of all proposals and sponsor contracts to ensure compliance with export control regulations. This includes:
- Screening foreign sponsors and collaborators using Visual Compliance software
- Partnering with UMB offices to ensure foreign individuals and entities are properly vetted
- Assessing international travel for UMB business to determine potential export control implications, including licensing requirements for samples, equipment, software, or technology being transported or shipped abroad
These screenings and reviews are routine practices designed to minimize risk and ensure compliance with federal regulations.
For detailed guidance on UMB’s export control program, policies, and procedures, please visit Export Compliance.