PI Responsibilities Regarding Export Control

For projects where protocols will involve actions or items that fall under federally-mandated export control laws and regulations, the Principal Investigator (PI) or co-PIs is/are considered the responsible individual[s] to ensure compliance, not only for him or herself, but by all other research and departmental personnel who engage in transactions related to the designated project. This may involve purchasing, shipping, foreign travel, learning to use a machine or particular technology, hiring persons from another country, or delivering project information at a conference.

Failure to follow prescribed federal, state, University and campus laws, regulations, policies, and procedures could result in sanctions.

Please use this as your “checklist” for reviewing compliance issues that may need to be taken care of. (More detailed information on each of these items can be found within the Export Control office website pages.)

If you answer “yes” to any of these questions, seek to learn and perform what needs to be done before the action is taken.

  1. Is my research, or a part of the actions taken during the research, going to fall under export control stipulations? See Fundamental Research Exclusion
  2. Are you planning/wanting to hire a foreign person (to be here on a visa) to work in your lab and on your project? See Employing Foreign Nationals
  3. Are you shipping an item to a foreign country? See International Shipping for Export Controlled Items
  4. Are you emailing a person in a foreign country – OR a foreign person within the U.S.? See FAQ on Dee​med Exports
  5. Are you delivering a lecture/poster presentation or any information to a foreign audience in a foreign country, OR to foreign persons within the U.S.? Or is one of your mentees? What’s the topic? See FAQ on Deemed Exports
  6. Are you traveling to another country for any reason and wanting to take your laptop or other electronic data storing device with you? What about your other researchers/students/postdocs, etc.? See International Travel with Export Controlled Items or Intel
  7. Are you using, within the research protocols, an export controlled technology or equipment? See Federal Export Control Regulations​
  8. Are you using, within the research protocols, a biologic agent or substance that might have another use that could be mis-used and cause national security or even local security concerns? See Dual Use Research Concern and Biological Agents in Research
  9. Have you made sure that all those who work on the project, or who are involved in financial or HR processes for your project, have completed the required training to understand their role in the processes that fall under Export Control? See Education and Training for Research Involving Export Control Regulations​


Questions? Contact the Export Control Office, christine.ahearn@cuanschutz.edu303-724-0245.