Collaborations

Academic exchanges and research endeavors are an increasingly globalized environment.  Some universities are finding themselves with non-traditional and complex cross-border collaborations which can include: developing joint degree programs with foreign universities; developing foreign branch campuses; or, engage in capacity building with foreign governments.

Collaborative research beyond fundamental research, including corporate and research with international research partners, and new collaborative corporate style instruments such as affiliation agreements, joint ventures, and consortia may be affected by trade compliance regulations. Sequestration has diminished state sponsorship which may lead faculty to engage in research with proprietary or national security restrictions that involve foreign persons or international collaborations.  These endeavors whether they cross borders or not, can be impacted by trade controls.  This in turn may require authorization from the federal government prior to proceeding with the activities, sometimes even as early as initial discussions, whether they are structured formally or informally. 

Study abroad programs have had minimal intersection with trade controls.  Study abroad programs typically do not involve the exchange of proprietary technical information that would be subject to restrictions.  There are "safe havens" that allow U.S. institutions of higher education to exchange academic information, conduct research, and other activities with foreign nationals.  These exclusions are: Educational Information, Publicly Available, and Fundamental Research. However, these exclusion are outlined in the regulations with very specific criteria.  If the activity does not meet the criteria exactly, the exclusion cannot be applied. 

Activities involving educational services to foreign nationals may require a license. Such activities can include: military training; academic services to a sanctioned countries, their nationals or individuals / entities in these countries.