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Export controls

Determine whether due diligence checks are needed

Please note: when planning a new project, export controls checks must be made in parallel to starting applications for funding and before inviting visitors to the University, not afterwards.

To determine whether export controls apply to your current or proposed project and require a licence: you must make the following checks (both phase I and phase II). If you’re satisfied that there are no concerns, before you can proceed with your project, we advise you to review the University guidance on research awareness first.

Phase I checks

1. Determine whether the information, research data, technology or knowledge you want to share is controlled

  • If it is controlled, fill in and submit an Export Controls Compliance request (online form) with the Regulatory Compliance Team. Furthermore, proceed to phase II checks below.
  • If it is not controlled, proceed to step 2

2. Determine whether an item you’re working with could potentially be used for military purposes

  • If you’re working with an item specifically designed for military use, or if you have concerns that an entity (institution, company or organisation) you're engaging with may be involved with items intended for military use, fill in and submit an Export Controls Compliance request (online form) with the Regulatory Compliance Team. Furthermore, proceed to phase II checks below.
    • When referring to an ‘entity’ this could include collaborators (formal or informal), funders, visitors that you are hosting, institutions that invite you as guest professorships, institutions where you are teaching abroad or consultancy work (either providing it or commissioning)
  • If you’re not working with an item specifically designed for military use, proceed to step 3

3. Determine whether if any there are any entity (institution, company or organisation) you’re working with, collaborating with or being funded by that is based in a key country. This would allow checks for End-users.

  • If they are based in a key country, fill in and submit an Export Controls Compliance request (online form) with the Regulatory Compliance Team. The form will ask you to specify what your listed entities, collaborators or funders intend to use your research for. Transfer of information, research data, technology or knowledge that is not controlled outside of the UK border could still be of concern, depending on the recipient and what they plan to use it for. Furthermore, proceed to phase II checks below.
  • If they are not based in a key country, proceed to phase II checks below.

Phase II checks

As US export legislation applies extraterritorially, confirm whether you're working with an item (physical good, software or information, data) imported from the US

  • If an item you’re planning to import from the US falls under either the US International Traffic in Arms Regulations (ITAR) or Export Administration Regulations (EAR), Fill in and submit an Export Controls Compliance request (online form) with the Regulatory Compliance Team. The team will advise on the appropriate measures required to be put in place to enable your research project to continue and provide assurance to the authorities that the University (and yourself) is complying with US Export legislation.