UNC-Chapel Hill works to maintain an open, welcoming atmosphere where visitors and scholars from all over the world can come to learn, collaborate, and perform research. The University’s Export Compliance Office (ECO) is the primary office responsible for assisting University faculty, staff, and students in ensuring export compliance on research projects.

The following factors are considered “red flags” and require ECO guidance (see also the Using Export Compliance Substatuses in RAM Tracker quick reference card).

• The following language in a solicitation or award:

1. Restrictions on information sharing for “national security” or “proprietary” reasons (e.g., publication or nationality restrictions and confidentiality provisions)
2. Controlled Unclassified Information (CUI)
3. Export-Controlled Information
4. Covered Defense Information (CDI)
5. Controlled Technical Information (CTI)
6. For Official Use Only (FOUO)

• Certain funding agencies are more likely to have the above language:

1. Department of Defense (e.g. Army Research Lab, DARPA, DTRA)
2. NASA
3. Department of Energy and National Labs

• Common clauses of concern:

1. DFARS 252.204-7000 (Disclosure of Information)
2. DFARS 252.204-7008 (Compliance with Safeguarding Covered Defense Information Controls)
3. DFARS 252.204-7012 (Safeguarding Covered Defense Information and Cyber Incident Reporting)
4. DFARS 252.204-7019 (Notice of NIST SP 800-171 DoD Assessment Requirements)
5. DFARS 252.204-7020 (NIST SP 800-171 DoD Assessment Requirements)
6. DFARS 252.204-7021 (Cybersecurity Maturity Model Certification Requirements)
7. DFARS 252.227-7025 (Limitations on the Use or Disclosure of Government-Furnished Information Marked with Restrictive Legends)
8. DFARS 252.225-7048 (Export-Controlled Items)
9. FAR 52.204-2 (Security Requirements)
10. FAR 52.204-21 (Basic Safeguarding of Covered Contractor Information Systems)
11. FAR 52.227-14 (Rights in Data – General)
12. FAR 52.227-17 (Rights in Data – Special Works)
13. FAR 52.240-1 (Prohibition on Unmanned Aircraft Systems Manufactured or Assembled by American Security Drone Act-Covered Foreign Entities)
14. ARL 52.004-4400 (Foreign Nationals Performing Under Contract)
15. ARL 52.005-4401 (Release of Information)
16. AFMC 5352.227-9000 (Export-Controlled Data Restrictions)
17. DEAR 952.204-71 (Sensitive Foreign Nations Controls)
18. NASA 1852.204-76 (Security Requirements for Unclassified Information Technology Resources)
19. NASA China entity prohibition re NASA funding
20. ER 52.0000-4017 (Foreign Nationals)
21. TAR 1252.242-72 (Dissemination of Contract Information)
22. DOE Foreign National Pre-approval (Form NETL-F)
23. DOE 10 CFR 810 Foreign National restrictions re NNSA/RSICC-issued software code
24. DHS: U.S. Citizen-only clauses

The primary office that is responsible for managing and negotiating sponsored research projects is the Office of Sponsored Programs (OSP). Please email OSP with any specific questions concerning your sponsored research.