Global partnerships enrich our university culture and are critical components to providing the highest quality education, research, and health care. Given the significance of research topics and rising need for international collaboration, one can imagine that such partnerships occur amidst increasingly complex relationships and regulatory environments.
Table of Contents
Disclosure of International Research Partnerships and Collaborations
Export Controls
International Regulations
Other Resources
Disclosure of International Research Partnerships and Collaborations
Issues surrounding foreign influence and international activities in federally funded research has been an evolving topic, in which the U.S. Government has shown increasing concern. These concerns include:
- Diversion of intellectual property to foreign entities
- Disclosure of confidential grant application information by NIH peer reviewers to third parties
- Failure of researchers to disclose research resources and support provided by other organizations, including foreign entities
This concern has led to increasing requirements for federally-funded researchers to disclose affiliations with foreign institutions in their proposal and reporting documents.
Disclosure Resources
Disclosure & Reporting Requirements for International Research
University resources around the government’s concerns and best practices
FAQ – Disclosure & Reporting Requirements for International Research Partnerships & Collaborations
Common questions answered about foreign partnership disclosure
Where to Disclose
- NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support
- NIH Pre- and Post-Award Disclosures
- NSF Biosketch Guide
- NIH Biosketch Guide
- NSF Current & Pending Support Guide – McKelvey Engineering Research Toolkit
- NIH Other Support Guide
Export controls
Export Control Laws apply not only to the physical export of technology overseas, but also to the deemed export of controlled technical information to foreign nationals within the United States.
What is a “Deemed Export”? Under both the ITAR and the EAR, the disclosure of controlled technical data to foreign nationals inside the United States is considered a “Deemed Export”.
Start Here: OVCR
Export Control Website
One-stop shop: regulations, policy, glossary, and how to determine and plan for export controlled research.
Start Here: WU Export Control Policy
Applicable regulations, WU policy, roles & responsibilities, and other considerations.
When to Contact the Export Control Team
ovcrexportcompliance@wustl.edu
- Sponsor proposal guidelines indicate that award terms may nullify the “fundamental research exclusion”
- restriction on WU’s right to publish or disseminate project results or information
- limits on participation or access by non-U.S. persons
- sponsor has prior approval rights over publication content (review is acceptable)
- Language in grant, contract, manufacturer, proposal, or purchase documents indicate that the item might have “dual use” or military use, or makes reference to ITAR or EAR.
- Items or technical information are produced for (or funded by) a defense, intelligence, or space related agency DoD, Army, Air Force, Navy, NSA, DHS, DARPA, IARPA, NASA or similar
- Research which involves:
- development of technology or equipment (may be for civilian use)
- defense, satellite, or space applications
- encryption technology
- biological or chemical threat agents and related medical remediation and diagnostics
- receipt of proprietary information from a sponsor
- Shipping or carrying controlled technology, equipment, or data overseas
- International collaborations where controlled data is shared
- Involvement with persons or entities from an embargoed or sanctioned country (Cuba, Iran, North Korea, North Sudan and Syria, others per OFAC.
- Unsolicited requests by foreign nationals to visit high technology facilities
Export Control Tipsheets (Selected)
- Know Which Types of Items are Controlled
- Know What is Excluded from Export Controls
- Spot Red Flags
- Export Control Decision Tree
- Prepare for International Travel
- More information and “how-tos” on the Export Control Website.
Contingent Worker Guidance – OVCR
Information on hiring contingent workers who will participate in WU research.
Export Control
Information and Technology Sharing Regulations
Applies to transfer of technical information or controlled items to foreign nationals or across U.S. boundaries
Prepare for International Travel (Export Controls)
Tip sheet: export control and technology issues for international travel
Sponsor Foreign Scholars and Visitors (Export Control Considerations)
Considerations for including foreign scholars, visitors, and students on controlled research
International Regulations and Your Project
Awards from foreign sponsors may come with financial and compliance regulations that are specific to the country or region of origin.
Check your award terms and conditions for applicable regulations.
Examples might include:
- The European Union’s General Data Protection Regulation (GDPR)
- The UK Bribery Act (See also the U.S. Foreign Corrupt Practices Act Policy)
Other Resources
Resources below provide information related to the international nature of today’s research.
Foreign Corrupt Practices Act (FCPA) Policy
Regarding improper payment to foreign officials and other improper business payments
Office for International Students and Scholars
WUSTL’s Office for International Students and Scholars enables international students and scholars to thrive academically and socially by meeting their unique needs and engaging them in American life and culture. Please contact your Department Administrator before contacting OISS.
Securing Controlled Unclassified Information (CUI)
Considerations for proposals and awards with terms related to CUI. Guide by JROC.
The EU’s General Data Protection Regulation (GDPR)
Privacy for individuals protected under the EU’s GDPR