What kinds of activities will raise Export Control concerns?
The vast majority of research and teaching activity at UMB falls within the fundamental research exclusion or another exemption to the EAR and ITAR regulations. Most items and information a UMB researcher wants to physically export outside the United States will not have a "dual use" or military application and should therefore fall under a broad exception to the licensing requirement.
However, the regulations place limits on transactions with certain countries, entities, or individuals. Some activities and items may raise "red flags" (warning signs) for potential issues or risks.
Contact the ORD export officer for a review if any of the following red flags apply to your research or activities:
- Funding opportunity or agreement restricts UMB investigators from publishing or freely disseminating their research results.
- Funding opportunity or agreement requires UMB to accept export-controlled technology.
- Equipment or materials needed for educational or research projects abroad will be exported (i.e., shipped or accompanying the researcher/faculty member or project leaders, including, for example, laptops, GPS equipment, other hand-held mobile devices, etc., any device that contains encrypted software, or research materials).
- Activity involves transactions with sanctioned countries or citizens of those countries, or with embargoed entities.
- Foreign nationals will have access to the source code for encryption software/technology.
In addition, the following red flags are usually addressed in routine sponsored programs proposal and/or award review and export review procedures:
- Foreign persons participate in the research.
- UMB partners with a foreign organization.
- UMB hosts foreign visiting scholars for research that involves certain specified technologies subject to export controls.