Butler Library

International Research/Export Control

International Research Procedures

To help researchers plan for risks and requirements that may be associated with international projects, the University has established Risk Management Procedures. The Procedures provide a mechanism for the project team and University to identify and manage risks. The Procedures also will assist the University in the development of a database of information relating to international projects, so that information can be more easily collected and shared.

International Research Risk Management Procedures

If a sponsored project proposal involves international research or service, the principal investigator or departmental administrator responsible for the proposal should notify the appropriate project officer in Sponsored Projects Administration as early as possible. Through a series of questions, the project officer will determine whether the project requires further review. The goal is to identify only those types of international projects that might need special assistance (e.g., a project requiring a long-term formal presence in another country or one operating within a country that is subject to export sanctions). The questions are listed on the Criteria Questionnaire (Annex A of the Procedures).

If the answer to one or more of the Criteria Questions is “yes,” the project officer will seek additional information about the project (Annex B of the Procedures). If warranted, the project may then be referred to the International Research Committee for further review.

The Procedures are not designed to second guess the scholarship of a project or to hinder the grant application process. The process is not intended to delay the review and submission of grant applications and, if necessary, can be completed after an application has been submitted. However, the process runs most efficiently when information is provided in a timely manner since significant lead time is often required, as for example, to acquire certain types of export licenses or to file necessary registrations with a foreign government when setting up an office in that country.

After the project has been funded, a more extensive post-award review will occur. Some of the questions considered at that point are detailed in the Post-Award Review (Annex D of the Procedures). Highly complex projects may require further post-award review by an ad hoc committee.

Resources such as the Office of the General Counsel and other offices within the University are available to provide legal, financial and other support to assist international project teams in finding solutions for implementing their service and research goals.

International Research Committee

The International Research Committee consists of Officers of Instruction and/or Officers of Research and representatives from the Office of the General Counsel, the Office of Sponsored Projects Administration, the Finance Division, and the Office of the EVP for Research. The Committee helps enable project teams and administrators to carry out the University's Risk Management Procedures