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UMB issues subawards to collaborators around the world. Before the agreement is signed by Sponsored Programs Administration (SPA) for the University, it is reviewed for export compliance.
SPA notifies the export compliance team when a subaward request involving a foreign organization is received.
The export compliance team screens the organization, its principal investigator, and administrative contacts against the U.S. lists of denied, debarred, and restricted parties.
Then, the scope of work is reviewed to determine whether exclusions or exceptions to the export control regulations apply. Factors in the review include the type of project (research, education, service), the subrecipient's country and any applicable sanctions and embargoes, and project activities such as shipment of material goods.
In most cases, no export or restricted party concerns are detected and SPA is so notified.
We work with the UMB principal investigator (PI) if we determine that a license or other export authorization from the U.S. government may be needed. The subaward cannot be issued until the license or authorization has been received or the export concern has been otherwise resolved.