NSPM Directive:  Export control training, as appropriate. Agencies should require that research organizations conducting R&D that is subject to export control restrictions provide training to relevant personnel on requirements and processes for reviewing foreign sponsors, collaborators, and partnerships, and for ensuring compliance with Federal export control requirements and restricted entities lists. 

Federal research agencies shall require covered institutions to certify that the institution requires covered individuals who perform R&D involving export-controlled technologies, to complete training on U.S. export control and compliance requirements. 

A covered institution’s certification requirement is met when the covered institution provides a written or electronic attestation to a federal agency that the covered institution has met relevant research security program requirements.

ORD provides training to UMB administrators as well as to faculty and investigators on a continuous basis. ORD has subject matter experts – the Research Security Manager (RSM) and the Export Control Officer (ECO) – to provide export control training. 

Training to central SPA and department administrators is ongoing and updates are presented routinely. SOPs and checklists are available as resources for capturing international collaborations or transactions with foreign entities. 

The RSM and the ECO review all proposals submitted to funding sponsors along with sponsor contracts. ORD reviews foreign sponsors and collaborations by conducting real-time research and screenings using the Visual Compliance software. Screenings are a routine practice within ORD, with the RSM and EC partnering with UMB offices to ensure foreign individuals and entities are properly screened. The level of the R&D and scope of work together determine the appropriate training required of investigators and their research teams.

In addition, the RSM and ECO review employees' travel internationally for UMB business to assess potential export control considerations, including export licensing requirements for university-owned samples, equipment, software, or technology employees intend to hand-carry or ship separately to their foreign destination.

For more information on UMB's export control program, policies, and procedures please visit Export Compliance.