Export Control Review Processes Office of Sponsored Projects Proposal and Award Phase
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/resourcecenter/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
Initial OSP Review Compliance Note 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 Phase YES Upon notification of award the CGA reviews the compliance notes and the award document to determine if a export control review is warranted.
Award Phase YES The proposal reviewer then sends an email to export@unm.edu 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 Phase: Notification of Determination YES 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.
Award Phase: Notification of Technology Control Plan YES If a TCP is needed the Export Control Officer will upload a TCP memo into the CayuseSP record.
Contact Information Adelicia Gunn UNM Main Campus Export Control Officer Phone: (505)277-2968 E-mail: export@unm.edu Deb Kuidis Manager of Industrial Security Facility Security Officer Phone: (505)277-2058 Email: dkuidis@unm.edu