1Fundamental research requires careful analysis
University research may qualify for exclusions or exceptions under certain conditions, but restrictions on publication, access, participation, or proprietary inputs can affect the analysis.
The institution should review the actual activity and agreement rather than relying on a project’s academic label.
2Screen the transaction and the context
Review classifications, destinations, parties, end use, end user, sanctions, licenses, exceptions, and institutional policy. Multiple regulatory frameworks may apply.
Screening is not a one-time name check. Changes in collaborators, scope, equipment, data, or destination can require renewed review.
3Document decisions and escalate early
Keep the facts, classifications, screening, approvals, conditions, and communications that support the decision. Researchers should receive practical instructions they can follow.
When uncertain, pause the affected transfer or access and contact the institution’s export-control or research-security authority.