Export Control: Red Flags
Red Flag items may involve an elevated risk of non-compliance with the EAR, reputational or political risk, and added administrative costs for managing high-risk engagements. A thoughtful review process can mitigate these risks, safeguard federal research funding opportunities, and comport with the expectations of federal agencies. Please contact the Export Control Office before proceeding with any of the following:
- Department of Defense or other military-related funding or collaboration: Army, Navy, Air Force, DARPA, Northup Grumman, etc.
- Space-related: NASA, European Space Agency, or other space agency funding; satellites, rockets, landing vehicles, etc.
- Encryption, advanced computing, and information technology: Source code, process design kits (PDKs), integrated circuits, etc.
- Nuclear: Weapons related as well as civilian or energy research
- Chemical or biological weapons: Select agents list or Dual Use Research of Concern
- Others: Includes UAVs (drones) or AUVs, robotics, rocket or missile technology, oil and gas exploration, acoustic technology or research, infrared cameras or focal plane arrays, certain sensors, etc.
- Payments: Such as travel reimbursements or for services or clinical trials to foreign individuals or entities
- Services: Such as consulting for or training foreign nationals, other than activities covered as “educational information” or “fundamental research”
- Restricted parties: See Export Controlled or Embargoed Countries, Entities, and Persons
- Sanctioned countries: Cuba, Iran, North Korea, Syria, Ukraine (Crimea, Donetsk, and Luhansk Regions)
- Foreign government involvement
- Foreign military: Providing information to a foreign military may be a defense service
- International travel
- International shipping: Red Flag Indicators in Export Transactions
Are there basic/fundamental research red flags?
- Publication or dissemination restrictions in award or BAA/RFP
- Foreign national restrictions or requirements for US citizens or US persons only
- DoD contracts/DFARS: “Distribution Statement B, C, D...” or “DoD only”
- Proprietary information: NDAs, CDAs, or other confidentiality agreements
Export Control Index
- Export Control
- Restricted Party Screening
- Controlled Technologies Lists
- Export Controlled or Embargoed Countries, Entities, and Persons
- Technology, Technical Data, and Software
- Technology Control Plan
- Frequently Asked Questions