Export Control Compliance 

Research at Kennesaw State University should generally be conducted openly and without restrictions. This makes it fundamental research, which is defined as “basic and applied research in science and engineering where the resulting information is to be shared broadly within the scientific community”
(National Security Decision Directive 189). Fundamental research is not subject to export controls when conducted within the borders of the United States. However, researchers may encounter export control restrictions if restricted equipment, materials, software, or information is shipped outside the United States. Similarly, a situation where a foreign national is given extensive access to restricted items or information in the United States may be considered a deemed export to that individual’s country.

image showing a padlock embedded into a digital screen

KSU is committed to compliance with Federal export control laws and regulations. Principal investigators of projects involving sensitive equipment, travel outside the United States, or items shipped outside the United States (including software or other technology, design plans, and technical information) need to consider whether their work is subject to export control restrictions. Violations of export controls can result in criminal and civil penalties against the individual responsible and/or the institution depending on the circumstances.

Please contact the Research Security Officer (ressecure@kennesaw.edu) in the Office of Research during the early stages of proposal planning to discuss potential exposure to export control laws and regulations, especially involving sensitive equipment or international research projects. Any suspected violations of export control laws and regulations should be reported immediately for investigation.

Research Security

The 2019 National Science Foundation JASON report affirms the importance of international collaboration in conducting fundamental research. Effective international collaboration, however, rests on a foundation of trust, which is achieved through disclosure, verifiable identifiers, and a commitment to transparency and openness by all parties. Malign foreign actors may try to exploit open science for their own benefit. Research Security at KSU seeks to protect intellectual property and limit malign foreign influence by engaging the research community and evaluating the risk of international collaborations.

Coordination with Research Security is highly recommended when collaborating with individuals and entities in Countries of Concern (COC) due to the well-documented risk that COC’s present to the research enterprise. Similarly, coordination with Research Security is highly recommended before any travel to COC’s to understand and mitigate the cybersecurity risk and threat to intellectual property. Cybersecurity risk during travel is not limited to COC’s, however; researchers traveling internationally should review these cybersecurity tips before their trip and consider borrowing a laptop from UITS.

Participation in a talent recruitment program is considered an outside activity and must be disclosed to both the university and to sponsors. Participation in a malign foreign talent recruitment program (MFTRP) could incur criminal or civil penalties under Federal law and will make the participant ineligible for Federal grants. Please review this university research policy related to talent recruitment programs and MFTRP’s.

Mandatory and Optional Training

Researchers applying to, or working on, Federal grants should take research security training, as mandated in the 2022 CHIPS and Science Act. The one-hour Consolidated Research Security course in the CITI training platform meets this Federal requirement and will need to be taken on an annual basis to remain compliant. Researchers working on Federal grants will also need to take Conflict of Interest (COI) training which is good for four years.

Further background on export control compliance is available in the CITI training course Export Control Awareness for Researchers which is recommended for researchers and administrators who may encounter export control regulations during research or travel. See this website for more information on CITI training resources and this website for COI requirements.