The action: Contact the export control office to determine if the organization is on the restricted party list.
The action: Contact the export control office well ahead of time so that the appropriate license can be obtained (licensing can take several months and a license is even required when giving a virtual presentation).
Travel with a ‘clean’ computer to in order to avoid unintended export control violations.
Do not access sensitive information on campus networks remotely while traveling.
If the faculty member attends the conference without the appropriate licenses contact the Export Control Office.
This is a violation of U.S. export control laws, even if the information presented at the conference is already published or the area is not a sensitive technology, and even if the faculty member is traveling on a non-U.S. passport.
The action: Contact ORS who will determine if the company is on the Department of Commerce Entity List, has been found to be in violation of US sanctions or is a subsidiary of a company on the List or in violation.
VPR will consult with other Penn offices if the proposed activity poses large institutional risk, including reputational risk.
The action: If the topical content includes sensitive technology, ensure screening occurs to determine if the institution that the student/post doc was previously affiliated with is on the restricted party list or will be funded by a restricted entity while at Penn.
Consult your BA or the export Control Office for screening assistance.
If the partner is on the restricted party list and the topical content is related to sensitive technology, export control office will assess whether visitor access to export controlled information/equipment/software requires licensing or must be restricted.
If the latter, develop security measures to ensure compliance.
The action: Since resources are made available to you in support of your research, this must be reported as Other Support, however, this would not qualify as a foreign component of the NIH research, as the foreign work is not part of the NIH-funded project.
The action: This appointment must be reported as Other Support. While monetary compensation is not received, the lab space, materials, and staff are resources provided in support of and/or related to the research efforts and must be disclosed. Other payments, such as travel or living expenses must also be reported. NIH, NSF, and DoD require applicants to list all positions and scientific appointments, both domestic and foreign, that are held by senior/key personnel that are relevant to an application. This includes affiliations with foreign entities or governments, such as titled academic, professional, or institutional appointments, whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
The action: This should be disclosed to Penn through the extramural activity disclosure process. It should also be reported as Other Support. Available resources in support of and/or related to an investigator’s research endeavors should be disclosed, even if they relate to work that is performed outside of a researcher’s appointment period.