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Export controls - What to do?

The first step is to use the list of key countries showing which are under current trade sanctions, including arms embargoes and other restrictions, to determine which of the following options is most suitable in your case.

Option 1

  • You are planning a new online ATAS-associated course or when adjusting an existing ATAS-associated course to be accessed remotely, export controls must be considered to determine if the content of the course is controlled. Non-ATAS-associated courses are exempt from Option 1 but do check if the other options below could apply.

Action:

  1. Determine whether the planned content for the course/material for virtual teaching is controlled
  2. Decide if you can alter the course to eliminate the controlled part of the content (preferred option) or if it is deemed impossible due to the type of course it is, then apply for an export licence, before putting the course online, by completing and sending Form 5c - Export Control for online courses with controlled items - Request for Export Licence to the ECC Team

If your assessment indicates that your project does not involve controlled goods and/or information you must still fill in Form 5c - Export Control for online courses with controlled items - Request for Export Licence to request due diligence checks on the institution/company the material you are preparing is for a specific student exchange agreement between the University and another institution or as part of a CPD program for a company.

Please remember that it is your responsibility to self-assess your research project. If you are uncertain, ECC Team can help.

Option 2

  • Your collaborator/funder is based outside the UK (in any other country that is not on the list of key countries). (Collaborator also includes potential co-authors of journal articles/reviews/book chapters/web pages/technical notes etc. (or any publishable materials). Collaborations include contractual as well as informal verbal agreements for potential co-authorship.)

Action:  Self-assess the research project. Refer to: SOP_ECC1 Export of Controlled Items from the University of Manchester.

If your assessment indicates that your project involves controlled goods and/or information, apply for a licence by filling in Form 5 – Export Control Project Self-Assessment: Controlled – Request for Export Licence and send it to ECC Team.

If your assessment indicates that your project does not involve controlled goods and/or information you do not need to inform ECC Team.

Please remember that it is your responsibility to self-assess your research project.   If you are uncertain, ECC Team can help. 

Option 3

  • Your Collaborator/funder is based in a key country (Collaborator also includes potential co-authors of journal articles/reviews/book chapters/web pages/technical notes etc. (or any publishable materials). Collaborations include contractual as well as informal verbal agreements for potential co-authorship.)
  • The home institution of the visitor of more than 5 working days is based in a key country

Action: Fill in Form 4 – Initial checks on Collaborator/Funder or Form 2 – Initial checks on Incoming Visitors and send it to ECC Team for further due diligence checks.

Option 4

  • The home institution of the visitor of less than 5 working days is based in any of the following seven countries: China, India, Iran, North Korea, Pakistan, Russia, Syria 

Action:  Fill in Form 2 – Initial checks on Incoming Visitors and send it to ECC Team for further due diligence checks. 

Option 5

  • The home institution of the visitor of less than 5 working days is NOT from one of the following seven countries: China, India, Iran, North Korea, Pakistan, Russia, Syria

Action: None necessary BUT:

  1. you need to inform the visitor if you will be sharing controlled information and that it is his/her responsibility to put in place an export licence to take any notes/data out of our country
  2. if you are going to continue the collaboration once the visitor returns to his/hers home institution, you will need to put in place an export licence to share the controlled information (via email, video conferences, telephone, etc.).

Action: Fill in Form 5 – Export Control Project Self-Assessment: Controlled – Request for Export Licence and contact ECC Team for assistance in submitting a licence application

Option 6: Travelling overseas

You are travelling out of the UK to any destination with controlled items and do not have an export control licence in place for the trip, please:

  1. Use webmail instead of Outlook to access your emails abroad. If you have an attachment that you suspect will have controlled data, please do not click on it to open it abroad
  2. Do not take your laptop containing your controlled data with you (you may want to take an empty computer- not University imaged- or just the information you require in a storage device, as an example)
  3. Do not use the University G or shared drives or other University servers to access your controlled information from abroad.

Staff and students who are working with controlled items and do have an export control licence in place for a trip abroad, can take computers, access email through Outlook, download attachments, etc., and undertake all controlled work that has been indicated in the export control licence application.

Apply for a licence or register to travel with controlled items to the EU by filling in Form 5b-Exporting controlled items to EU (intra-community) and sending it to ECC Team.

If you are uncertain, ECC Team can help.

Preliminary checks on collaborator/funder

If you want to perform preliminary checks on your Collaborator/Funder browse the links below.

You can use ‘Control+F’ (for Windows users), or ‘Command+F’ (for Mac users) to search for the collaborator/funder name in lists 1 to 4. List 5 is a search engine, type in your collaborator/funder name.

1.      US Embargoed list Entity List

2.      US Embargoed Unverified List

3.      OFAC SDN list

4.      UN sanctions list

5.      UK Consolidated List of Targets

Note: ECCPT performs further due diligence checks. If your situation refers to Option 1 and you have checked the lists above you still need to submit Form 4 – Initial checks on Collaborator/Funder or Form 2 – Initial checks on Incoming Visitors depending on your case.