Before You Conduct Research/Services for a Foreign Sponsor

Whenever your research will be funded by a foreign sponsor, take note of the following:

Potential Red Flags - How well do you know the potential sponsor?

• How well do you know the customer/sponsor?  Have you worked with them before or are they "cold calling"?
• Why do they have an interest in your research?  Is it relevant to their business?  Are they transparent about this?
• Do they show an interest in sensitive topics that are outside the scope of your research?
• Do you notice any other red flags or suspicious elements?

 Fundamental Research 

Any and all projects funded by a foreign sponsor must be for Fundamental Research. Research results that do not qualify as Fundamental Research may be subject to export controls restrictions and could require a US government license in order to be delivered to a foreign sponsor.

Restricted Parties

Per the Policy on International Engagements you will need prior-approval from the Office of Research Security if your foreign sponsor is a restricted party.  Always perform screening and due diligence on potential sponsors in foreign countries before working with them.

Military (or Foreign Government) Sponsors

If the foreign sponsor is a military unit or military organization in another country, you may be providing a Defense Service by performing the research.  Such activities always require US Government pre-approval.

Generally Prohibited Activities with Foreign Sponsors

If the research is in any of the following areas (even if publishable Fundamental Research), it will generally be prohibited:

• Nuclear explosive devices
• Missiles, rocket systems, and unmanned aerial vehicles
• Chemical or biological weapons (including plants for their production)
• Military intelligence

Shipments, Travel, and Transfer of Data/Software/Materials

Any shipments or material transfers to the foreign sponsor need to be evaluated for export controls as licenses may be required from the U.S. Government.

Be mindful of travel-related export controls restrictions that could apply when visiting a foreign sponsor.

Be cautious about sharing any unpublished information with any foreign sponsor or entity.