While the University of Denver’s policy on export controls is based primarily on the need for open access and publication and preserving the protection of the fundamental research exemption, it recognizes there may be times when a license is required when controlled equipment or technology is an important element of a research project. When this is the case, it is imperative that the researcher recognize they are dealing with potentially export controlled equipment or technology and work closely with ORSP to determine whether a license is needed for the completion of the research project and whether the University will consider applying for one in accordance with its policies.
In the event a license is required, the researcher’s help is critical in determining the classification of the controlled item. This may require the researcher contacting the vendors providing the controlled equipment or technology for their assistance with this determination, as well as negotiation by ORSP. The researcher’s help is also required for preparing the technical aspects of an export license application and for responding to any federal agency questions regarding the research. If a license is granted, there are generally provisos that are part of the license that dictate how the equipment or technology may be used in the course of the research that the researcher is responsible for complying with.
As ORSP is responsible for the management of the University of Denver’s export control issues and any licenses that may be required for University of Denver research, it is imperative that the researcher engage ORSP as soon as an export control issue is identified so they can address the issue in a timely manner so there will be no delay of the research project. This may take several months, so connecting with ORSP as soon as possible is imperative.
For more details regarding the license application process, please visit the Bureau of Industry and Security.