Export control regulations are a complex set of federal laws designed to control the transfer of information, technology, software, other items, and services considered to be important to the United States due to concerns regarding national security, economic competitiveness, or support of international treaties and foreign policy.

Exports include:

  • Transfer of controlled physical items to foreign countries or to non-US persons in or out of the United States.
  • Transfer or disclosure of information or technical data (even visual disclosure through observation) to foreign countries or non-U.S. persons in the United States or abroad.
  • Provision of services outside the United States or to entities outside the United States.

Georgia Tech policy is that all faculty, students, and staff comply with the United States Export Control Regulations, which include the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and related export control trade sanctions and embargoes. 

At Georgia Tech, the export control team sits within the Office of General Counsel (OGC). 

Within the Office of Sponsored Programs (OSP), the Corporate & International Contract team executes sponsored research agreements when the sponsor is an international organization. All international sponsor proposals should go through a visual compliance check, regardless of whether we have worked with that sponsor in the past or not. Proposals are reviewed for export control concerns related to national security, foreign policy, anti-terrorism, and/or non-proliferation. Export review requests can also be generated for subject matter review by other teams within OSP.  A statement of work for a modification also needs to undergo subject matter review.

When a Department routes a proposal through e-routing, one of the compliance checks is export control. If “foreign entity” is selected by a Department, the proposal will be automatically routed to export and a file will be created in the system. The export review status will be shown as a banner in e-routing. PIs and Contracting Officers look at the export control banner in e-routing to see if the file says “Complete.” This “complete” notice indicates to Contracting Officers that export has reviewed the proposal and the file is cleared to send out. 

Contracting Officers do not send international proposals to sponsors without receiving clearance from the export team in e-routing. An export file may also be created by a Contracting Officer if it is for subject matter review.  Note that export control reviewers may contact the PI for additional information as needed. The Export Control team is currently is asking for a minimum of 30 days to complete export review. If your proposal is time sensitive, please email export at export@gatech.edu noting the deadline and copy your contracting officer. 

If you have any questions about this article, please contact Josh Rosenberg at josh.rosenberg@business.gatech.edu. For specific questions related to international proposals, please contract Yatri Amin in OSP at yatri.amin@osp.gatech.edu.