International Engagement

Before collaborating with foreign individuals and entities, Restricted Party Screenings (RSP) must be performed to ensure that UNC Charlotte activities comply with export laws and sanctions regulations.

International collaborations and engagements that involve both (i) a country of concern and (ii) emerging technology must be escalated to the Research Security team for evaluation.

Countries of concern: China, Iran, North Korea, Russia, Qatar, Saudi Arabia, and the United Arab Emirates.

Emerging technology includes:

• Biotechnology 
• AI and machine learning 
• Positioning and navigational technology 
• Microelectronics or Semiconductors 
• Advanced computing 
• Data analytics technology 
• Quantum information and sensing 
• Additive manufacturing 
• Robotics and autonomous systems 
• Brain-computer interfaces 
• Hypersonics

If you are unsure whether your collaboration involves emerging technology, contact the Export Control Officer or Research Security Coordinator.

What is an Active Collaboration?

For purposes of this certification, active collaboration generally refers to an ongoing or planned research or scholarly relationship in which an individual and a prohibited entity (or an employee of a prohibited entity) work together toward a shared research, development, or scholarly objective. Active collaboration typically involves the exchange of research ideas, data, materials, technology, software, funding, or other resources that contribute to a common project or research outcome.

Examples of active collaboration may include:

• Conducting a jointly planned research project.
• Co-authoring manuscripts based on collaborative research.
• Sharing unpublished research data, materials, software, or technology for a common research effort.
• Serving as a co-investigator, collaborator, or key personnel on a research project.
• Participating in a research agreement, memorandum of understanding, or similar arrangement involving collaborative research activities.
• Supervising or conducting research with personnel employed by a prohibited entity.

Activities that generally are not considered active collaboration

The following activities, by themselves, generally do not constitute active collaboration:

• Attending the same conference, workshop, or seminar.
• Asking or answering questions during conference presentations.
• Serving on the same professional society or conference committee.
• Citing or discussing published research.
• Peer reviewing manuscripts or grant proposals.
• Exchanging information that is already publicly available.
• Having incidental or one-time professional interactions that do not involve a shared research effort.

When to contact the Research Security Team

If you are uncertain whether a relationship constitutes an active collaboration, or whether an institution or individual is associated with a U.S. prohibited entity list, contact the Export Control Officer at exportcontrol@charlotte.edu. The Export Control Office can review the specific facts of your situation and provide guidance.

You may be considering signing an agreement with a foreign entity in your personal capacity. UNC Charlotte highly recommends that you send any such agreements to your Department leadership and the Office of Legal Affairs for review. Department leadership should review your agreement to ensure it does not conflict with UNC Charlotte policies for conflicts of commitment or conflict of interest. The Office of Research Commercialization and Development (ORCD) can also facilitate a discussion about intellectual property.

Please be aware that only persons with designated signature authority are permitted to sign any agreements on behalf of the University. If your international collaboration will involve a contract or agreement between the international entity (institution, university, company, etc.) and UNC Charlotte, please review the University’s International Exchange Agreement Procedure webpage and reach out to the appropriate University office.

If you are transferring or receiving data as part of your UNC Charlotte responsibilities, you may need a formal agreement.

• Exchanging data will likely require a Data Use Agreement (DUA). 
• Sending or receiving materials requires a Materials Transfer Agreement (MTA). 
• If you plan on sharing data, materials, or information in your international collaboration, check with Export Control to see if a license is required.

Please review the Guideline For Research Data Security webpage and reach you to the appropriate University office.

If your collaboration could potentially involve inventions or the creation of new intellectual property (IP), be sure to contact the Office of Research Commercialization and Development (ORCD) prior to the start of the collaboration. This will ensure you are aware of all the options and impacts regarding the commercial potential of your research.

It is in your best interest to disclose all foreign relationships and activities. Being transparent helps you collaborate while staying in compliance with federal regulations and UNC Charlotte policies.

• Obtain prior approval for any research engagements or appointments with foreign entities.
• Disclose travel, housing, gifts, or other types of compensation received from any foreign entities. 
• Report any support or compensation to federal sponsors as Other Support/Current & Pending Support to the Office of Research Services (ORS), if applicable.
• Researchers with Department of Energy (DOE) funding should review DOE Order 486.1A, Foreign Government Sponsored or Affiliated Activities (especially Attachments 1 and 2) for additional restrictions regarding participation in Foreign Talent Recruitment Programs.
• If you work with export-controlled technologies, also check with the UNC Charlotte Export Control Office (exportcontrol@charlotte.edu) regarding your collaboration.

If you are traveling outside of the United States:

• Review the information and resources available on the International Travel Resources webpage.

• It is recommended you register your international travel by completing the Travel Authorization form on the Financial Services webpage, as well as completing the International Travel with University-Owned Equipment form if you are taking any UNC Charlotte owned equipment.

If you are hosting an international visitor: 

• Review the Hosting International Visitors webpage, as you may need to request a review by the Export Control Office. 

If you are hosting a visiting scholar:

• Review the Resources for Visiting Scholars and Faculty webpage for hosting, and reach out to the International Student and Scholar Office (ISSO) if you have questions.
• Review the J-1 Visiting Scholars policy.

Report the effort from the visiting scholar as Other Support to federal sponsors, as applicable.

• Communicate early and often: Reach out to UNC Charlotte’s Export Control and Research Security Program for guidance or with questions. These staff will help you collaborate successfully while staying in compliance with federal regulations and UNC Charlotte policy.
• Be aware of foreign talent recruitment programs: The U.S. Federal government has placed restrictions on researchers participating in Malign Foreign Talent Recruitment Programs. Review ORPI’s webpage on Foreign Talent Recruitment Programs for more information.
• Traveling with electronic devices: Caution should be taken when traveling with laptops and other electronic data devices, as there is an increased risk that your devices may be compromised especially when traveling internationally. Government authorities may ask you to provide access to electronic devices when entering or exiting a country. It is a best practice to limit the number of devices and use a “clean” laptop with only what is needed for any presentations. Review the International Travel Page for more information.
• Transparency in Disclosure: All investigators on sponsored projects should check the sponsor’s current disclosure requirements carefully (especially with international funding sources) and, if in doubt, contact Sherry Loyd in the Office of Research Protections and Integrity (ORPI) for disclosure assistance or further guidance.