FAQs

During the Pre-award phase, you will be notified of any DFARS clauses relating to CUI or Export Control, and you may be asked to undertake additional training as needed. During proposal and award review, you may be notified of:

• Export control restrictions (e.g., ITAR/EAR applicability)
• DFARS clauses related to Controlled Unclassified Information (CUI) (e.g., 252.204-7012, 252.204-7021)
• Sponsor-specific restrictions on access, publication, or foreign national participation

Yes, export control and CUI requirements can be introduced or modified at any point in the project lifecycle, including:

• Contract modifications
• New funding increments or task orders
• Sponsor direction or regulatory changes

Any such changes will be reviewed and negotiated by Grants and Contracts, with support from the RSECO.

Yes, business and personal travel is generally allowed apart from university-related travel to restricted countries. However, if you are working on an export-controlled project, you may be subject to additional requirements that would compel you not to travel internationally with your UNT laptop or any devices that may store data from that project. When you register for international travel, you will be contacted and asked more about the devices you plan on taking and the type of work you are engaged in. The RSECO may follow up with you if additional guidance is necessary. 

It depends. Sponsored research should not be taken out of the country, and that includes taking a university-issued laptop if information is saved to that computer. Travelers going to China on personal travel may not take their UNT laptops with them under any circumstances due to Chinese laws banning certain data encryption technology. Travelers going to high-risk destinations may borrow a loaner laptop from ORIC.

• Lead by example and follow all required controls
• Provide professional, constructive reminders when appropriate
• Escalate concerns if necessary:
• First: Supervisor or PI
• Then: RSECO

All research staff associated with export activities will attend an Export Control training session annually and will be asked to review and sign a Technology Control Plan (TCP) prior to engaging in an export-controlled activity. Attendees of ITAR-controlled conferences will need to attend an Export Control training session prior to attending the conference. It is ultimately the individual’s responsibility to comply with export control laws, regulations, policies, rules, and procedures, which is why this training is required prior to engaging in export-controlled work.

On-demand export control training can be accessed through CITI training. You can also attend the live training sessions hosted by the Research Security and Export Control Officer or request a targeted training for your research group. https://www.citiprogram.org/

Some items shipped overseas may need export control approval. Please check with your department’s shipping liaison or the Research Security and Export Control Officer before any international shipping.

Yes. Certain types of information shared with a foreign national can constitute an export. PI’s working on sponsored projects must adhere to information access protocols when conversing with foreign nationals.

A deemed export occurs when controlled technical information is shared with a foreign national inside the United States. This is treated the same as exporting the information overseas.

CUI is sensitive information provided or generated under a federal contract that requires safeguarding but is not classified. Handling CUI may require the use of approved systems and restrictions on storage, transmission, and access.

No, unless explicitly authorized as controlled data must be stored only on approved systems and local lab equipment or personal devices typically do not meet compliance requirements. Follow your project’s Technology Control Plan (TCP) and system authorization guidance.

Potential export violations should be reported to the Research Security and Export Control Officer (via oric@unt.edu) as soon as you become aware of them. Do not hesitate or try to gather additional information. There can be civil penalties for failure to report potential violations immediately.

If you have any questions, please contact the Research Integrity and Compliance Office at oric@unt.edu or the Research Security and Export Control Officer, margaret.cochran@unt.edu.