When conducting research off-campus or with researchers abroad, researchers should be aware of procedures regarding collaborators and regulations regarding fundamental research.
Screen collaborators and institutions
Most interactions with the residents of the comprehensively sanctioned countries are prohibited.
In addition, some entities (such as companies, organizations, and universities) and individuals may have prohibitions that limit or forbid your interactions. Before collaborating, screen collaborators and their home institutions for restricted parties.
If your screening identifies a restricted party, contact MIT Export Control. MIT Export Control will help resolve whether the match is a false positive and whether to move forward with the collaboration if not. You may not be able to transfer certain items to restricted parties, making the collaboration impractical. Collaborating with parties looked at suspiciously by the US government may also impact applications for federal funding.
Report informal international collaborations
Informal collaborations, where there is no written agreement or exchange of funds, can still leave MIT researchers vulnerable to legal or financial penalties. Researchers (including staff, postdocs, and graduate students) are encouraged to report their informal collaborations in the Informal International Collaborations (IIC) tool. The VPR Compliance team will review each submitted collaboration and contact the researcher with any questions or concerns.
Check that off-campus research is fundamental research
Research conducted outside the MIT campus can still be considered fundamental research, as long as it meets the following criteria:
- Places no restrictions on publication
- Places no restriction on who may participate
- (If ITAR-regulated) is performed at a US institution of higher learning
If your intended collaboration does not meet those criteria, contact MIT Export Control.
Screen members of consortia
Screen potential members of consortia, institutions, and principal individuals if known. Contact MIT Export Control before joining a consortium with restricted parties in their membership. The amount you interact with restricted parties, the subject matter you will be addressing, and which restricted lists they appear on all affect whether you will be able to join the consortium.
For an MIT-sponsored consortium, add this statement to the announcement and registration material:
MIT (consortium name) is open to anyone in the world, with the exception of United States embargoed countries (Iran, Cuba, Syria, North Korea, or the Crimea, Donetsk People’s Republic or Luhansk People’s Republic areas of Ukraine), regardless of age, nationality, gender identity, cultural identity, or political viewpoint. US law prevents MIT from providing services to persons ordinarily resident in Iran, Cuba, Syria, North Korea, or the Crimea, Donetsk People’s Republic, or Luhansk People’s Republic areas of Ukraine and to parties blocked by the US Treasury Department.
Review other export control topics
International research collaborations likely involve additional activities, such as shipping items abroad. Review export control procedures on related topics:
- Shipping (for example, to deploy instrumentation internationally)
- Traveling
- Providing services such as instruction, mentoring, training, consultation, technology transfer
Assess and mitigate risk
Review Assessing and Mitigating Risk to understand whether the collaboration poses risks to you or your research program.