Continual Monitoring:

Award Receipt and Management

Once an award has been received by MIT, the administrator still needs to remain vigilant about recognizing export control issues in the following areas:

· Award Document

· New Areas of Inquiry by Researchers

· Other Possible Situations

· Outside the Scope of Research Projects

 

 

Award Document

When the award is received, it should be carefully examined to confirm that it does not contain any terms or conditions that would restrict the disclosure or dissemination of research results, or place any constraints on foreign nationals being able to work on the project at MIT.  (It is not uncommon for the terms to change between Proposal Submission and Award.)

 

Look for any restrictions in

· publication

· dissemination of research results

· constraints on participation by foreign nationals

· dissemination to foreign nationals

 

 

New Areas of Inquiry by Researchers

Researchers may develop new areas of inquiry that were not part of the original Statement of Work, or that the researchers wish to share technology or software that was not contemplated in the proposal phase of the research project.

Sponsors may also become aware of export control issues on their side and wish to impose new export control restrictions that were not part of the original proposal.

 

Other Possible Situations

These are situations where the need for a license was not evident at the beginning of the project but ultimately resulted in the need for a technology review and possible license.

 

Where to Send the Prototype
a researcher may be required to build a prototype for a sponsor as part of the deliverables; when it comes time for delivery, it is discovered that the sponsor wishes to have the prototype sent to its parent company in Europe.

Researcher Leaving MIT
Another scenario may be one where a researcher decides to leave MIT to work at another in a foreign country and wishes to take her laboratory equipment with her.

 

Export Control Issues Can Arise Outside of Research Projects

Contract administrators need to be aware of all the diverse places wherein these export control issues can be found. 

For example:

· Researchers may receive forms or agreements with export control provisions when they try to purchase materials or software.

· Researchers may wish to travel to certain countries that they or the Purchasing Office recognize as embargoed when a purchase order is being prepared or processed.

· Researchers may wish to collaborate on publications with foreign colleague or share equipment with them, outside the standard research project procedures.

 

MIT recognizes that providing training to all members of the research community is important if awareness of these issues is to be developed.  When it doubt, always ask.

MIT Office of Sponsored Programs