Jump to section:

  1. Whom do I contact?
  2. What are export controls?
  3. How can export controls apply to research?
  4. How will I know if export controls apply to my research?
  5. If I think export controls may apply to my project, what should I do?
  6. If export controls apply to my project, what should I do?
  7. What can I do to ensure compliance with export controls?
  8. Is training available?
  9. What can happen if I fail to comply with export controls?

1.  Whom do I contact?

The Division of Sponsored Programs (DSP) provides oversight of export control compliance for sponsored research projects. 

2.  What are export controls?

Export controls are federal laws that protect national security and the domestic economy by restricting the export of goods, technology, related technical data, and certain services.  

3.  How can export controls apply to research?

Research activities may be subject to export controls if they involve the actual or “deemed” export of goods, technology, or related technical data that are: 

  • dual use” (commercial in nature with possible military application), or  

  • inherently military in nature.   

Export control regulations exclude fundamental research—defined as basic or applied research in science and/or engineering at an accredited U.S. institution of higher education where results are ordinarily published and shared broadly within the scientific community. In these cases, information (but not materials or technology) resulting from the research is not subject to export control restrictions. 

Work in the following areas is considered high risk:  

  • Engineering  

  • Space sciences  

  • Computer science  

  • Biomedical research involving lasers  

  • Research using encrypted software  

  • Research involving controlled chemicals, biological agents, and toxins 

4. How will I know if export controls apply to my research?

Situations that may implicate export controls include: 

  • Presentations or discussions of previously unpublished research at conferences or meetings attended by foreign national scholars  

  • Research collaborations with foreign nationals or participation in technical exchange programs  

  • Transfers of research equipment abroad  

  • Visits to your lab by foreign scholars  

  • Sponsored research from agencies such as the Department of Defense  

5.  If I think export controls may apply to my project, what should I do?

When routing a proposal or contract, indicate potential export control applicability by selecting “yes” on the DSP routing form question about export controls. You will receive an automatically generated email requesting additional information. 

The export control coordinator will review your responses and can help determine whether export controls apply to your specific situation. 

6.  If export controls apply to my project, what should I do?

The export control coordinator will help determine the actions required to ensure compliance. These may include:  

  • Creating an access control plan (a document outlining procedures for limiting access to export-controlled items or technology)  

  • Increasing record keeping  

  • Requesting export licenses from the federal government 

Required compliance measures must be in place before project contracts are signed or grant funds are awarded. The principal investigator is ultimately responsible for maintaining compliance. 

7. What can I do to ensure compliance with export controls?

  • Do not take export-controlled information on electronic devices when traveling internationally, and ensure items you carry are not export controlled.  

  • Do not enter into agreements that limit your ability to publish research or restrict participation in the project. 

  • Contact the export control coordinator with any questions about applicability. 

8.  Is training available?

Yes. Contact export-control@uiowa.edu to arrange individual or group training sessions. 

9. What can happen if I fail to comply with export controls?

Noncompliance can result in serious consequences for both the university and the researcher, including fines of up to $1,000,000 and/or imprisonment of up to 10 years for individuals. These penalties apply per violation, and multiple violations can result in significantly greater penalties. Researchers may also be held personally liable and subject to criminal proceedings.