export control processes for sponsored projects. proposal phase
DESCRIPTION
PI Completes Export Control Section in Cayuse SP 1. Have you signed or been asked to sign a DoD Form 2345 Militarily Critical Technical Data Agreement related to this project? YES NO If the PI answers YES to this question- contact Deb Kuidis for a copyTRANSCRIPT
Export Control Processes For Sponsored Projects
Proposal Phase
PI Completes Export Control Section in Cayuse SP
• 1. Have you signed or been asked to sign a DoD Form 2345 Militarily Critical Technical Data Agreement related to this project?
YES NO• If the PI answers YES to this question- contact
Deb Kuidis for a copy
PI Completes Export Control Section in Cayuse SP
• 2. Do you anticipate that the project work may involve:
• A) Travel outside the US and/or sending/transporting/transmitting/carrying any material or equipment related to this project outside the US (examples include: GPS, other equipment, biologicals, diagnostic kits, reagents)?
YES NO If the PI states YES the following screen will appear:
PI Completes Export Control Section in Cayuse SP
The PI is to complete this section AND submit an ECES form to be uploaded into the CayuseSP record prior to being sent for an export review.
The proposal reviewer needs to ensure that is an ECES is required it is filled out completely and uploaded into CayuseSP at the proposal stage
PI Completes Export Control Section in Cayuse SP
2. Do you anticipate that the project work may involve:
b) Foreign nationals and/or persons holding dual citizenship (note: Green Card holders are considered U.S. Persons)?
YES NO c) Transmitting funds (through payments, for example) or goods or technology to Cuba, Iran, Syria, Burma (Myanmar), or Sudan? http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx
YES NO
The PI is to complete this section AND submit an ECES form to be uploaded into the CayuseSP record prior to being sent for an export review.
The proposal reviewer needs to ensure that is an ECES is required it is filled out completely and uploaded into CayuseSP at the proposal stage
PI Completes Export Control Section in Cayuse SP
3. Some types of research may have export control implications even if all work is conducted within the U.S.
The PI is to complete this section AND submit an ECES form to be uploaded into the CayuseSP record prior to being sent for an export review.
The proposal reviewer needs to ensure that is an ECES is required it is filled out completely and uploaded into CayuseSP at the proposal stage
Export Control Exclusion Screening Form
It is the proposal reviewers responsibility to collect and upload the ECES document into the CayuseSP record BEFORE sending the project for an export review.
Please endure that each question is answered and that the PI provides additional information on the second page of the document as warranted by their responses.
Does this project involve potential export control issues?
Red Flags • TECHNOLOGY TO WATCH FOR: – Semiconductors– Lasers, Sensors, & Optics – Robotics– UAV’s (Unmanned Aerial Vehicles)– Information Systems– Navigation Systems – Aeronautics – Marine and Space Systems – Cryptography/Encryption technology – Nuclear
Red Flags • TERMS TO WATCH FOR
– Export Control (generate/receive)– Sensitive Unclassified Information– Restrictions
• Publication “Approval”/Trade Secrets• Foreign Nationals • NDA’s
– Military/ Defense applications – DD Form 2345: Military Critical Technical Data Agreement – Technology Control Plan – NEW: Safeguarding of Unclassified Controlled Technical Information:
DFARS Clause 252.204-7012– International Travel
Red Flags
• TERMS THAT INDICATE A NEED TO CONTACT INDUSTRIAL SECURITY (Deb Kuidis):– COMSEC– OPSEC Plan – FOUO– Classified Information – Cleared Defense Contractor (CDC)– Security Clearances – DD form 254: Contract Security Classification Specifications – DD Form 2345: Military Critical Technical Data Agreement
Red Flags • If ANY of these questions in the Cayuse Export Control Section
are answered YES and/or you identify any red flags in the proposal, create a compliance note in the record indicating that an export control review is needed at time of award
Award Stage
Upon notification of award the CGA reviews the compliance notes and the award document to determine if a export control review is warranted.
Award Stage
The proposal reviewer then sends an email to [email protected] indicating that an export review is needed and detailing the reason for the review. (Example: Publication Restriction or International Travel
Documents Needed for Export Control Review
• Completed Export Control Questions in CayuseSP• Completed ECES Document • Award Document • Full Proposal • Budget• Budget Justification • Correspondence • Statement of Work • Any associated unfunded agreements All documents should be uploaded into the CayuseSP record prior to the project being sent for an export review.
Award Stage: Notification of Determination
The CGA will be notified via e-mail of the export control determination. In addition, the Export Control Officer will make a note of the determination in the compliance notes section of the CayuseSP record.
If a TCP is needed the Export Control Officer will upload a TCP memo into the Cayuse record.
Contact Information Adelicia Gunn, MPA
UNM Main Campus Export Control Officer Phone: (505)277-2968
E-mail: [email protected]
Deb Kuidis Manager of Industrial Security
Facility Security Officer Phone: (505)277-2058
Email: [email protected]