Export Control Policy and Procedures
It is the policy of Brown University that all personnel, including faculty, staff, students, visiting scientists and scholars, post-doctoral fellows, and all other persons retained by or working at the university comply with all U.S. laws and regulations as they relate to university activities including all export control regulations. Brown’s Export Control Policy outlines the responsibilities of all Brown personnel and the Export Control Compliance Manual provides information, resources, and guidance.
As an accredited U.S. academic institution, the vast majority of the university’s activities are shielded from Export Controls under the Fundamental Research, Educational Information and Public Information Exclusion.
Export Control Procedures at Brown University
Brown has established a network of internal controls to alert compliance officers when an activity may require export control review. The Office of Research Integrity (ORI) collaborates with several departments to carefully evaluate proposed transactions and determine whether they fall on the Commerce Control List (CCL) or the U.S. Munitions List (USML). Additionally, the departments screen the transactions for involvement with Restricted Parties. Here are some examples of ORI’s collaboration with other departments:
Reviewing research grants and agreements for potentially restrictive clauses: ORI works with the Office of Sponsored Programs (OSP) and the Technology Ventures Office (TVO) to ensure that all incoming research agreements are reviewed for potentially restrictive publication or participation clauses.
Purchasing equipment/technology/software: ORI collaborates with Purchasing Services to review and classify certain purchases to be made via a Purchase Order.
Transfer of materials or animals that require Material Transfer Agreements: ORI works with the Technology Ventures Office (TVO) to review language for incoming MTAs, and to screen materials being shipped internationally by Brown personnel under an outgoing MTA.
Shipping biological materials: ORI works with Environmental Health and Safety (EHS) to resolve any potential “hits” that EHS may encounter as it screens biological materials being prepared for shipment.
International Travel and Collaborations: ORI receives alerts from the Internal Review Board (IRB) and from OSP regarding studies that involve international travel or international collaborations. ORI screens potential international collaborators and provides the PI with additional information regarding export controls.
University Export Control Advisory Group
The Brown University Export Control Advisory Group meets semi-annually, or more frequently, if necessary. The Group provides guidance to the VPR, ORI and the ECO regarding export control issues at Brown University, including but not limited to, assisting with the development of policies, guidelines, procedures, training programs pertaining to export control and facilitating communication and dissemination of information about export control compliance among the Brown community. Membership is comprised of representatives from the Brown research community, the Office of the General Counsel (OGC), the Export Control program, the Office of Sponsored Research, the Office of Technology, Ventures and Licensing, Environmental Health & Safety, the Office of International Scholar and Students Services, and the Office of Purchasing and Insurance.