Western Michigan University
Export Control and Open Research Compliance Review Worksheet
Western Michigan University (WMU) is required to demonstrate its export control due diligence and to
document its adherence to United States (U.S.) export controls and trade sanctions laws.
U.S. export control laws, including the Export Administration Regulations (“EAR”), International
Traffic in Arms Regulations (“ITAR”) and Office of Foreign Assets Control (“OFAC”), require that
WMU obtain an export license prior to providing controlled technologies to certain foreign
national employees, students, researchers or collaborators. The decision whether or not to file
and/or pursue an export license application is at WMU’s sole election.
Export controls, when applicable, may require WMU to receive authorization from the U.S. Government in
the form of an export license. An export license permits "controlled" tangible items or software to be sent
outside of the U.S., or for controlled information or software code to be shared with foreign persons in the
U.S. ("deemed exports") or abroad.
An export is any oral, written, electronic or visual disclosure, shipment, transfer or transmission
of commodities, technology, information, technical data, assistance or software codes to:
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anyone outside the U.S. including a U.S. citizen
a non-U.S. individual wherever they are (deemed export)
a foreign embassy or affiliate
Methods of Disclosure Include:
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Fax
Telephone discussions
E-mail communications
Computer data disclosure
Face-to-face discussions
Training sessions
Tours which involve visual inspections
Access to sensitive laboratories
Export controls are frequently, but not exclusively, associated with items, information or software
within the following general areas:
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Chemical, Biotechnology and Biomedical Engineering
Materials Technology
Remote Sensing, Imaging and Reconnaissance
Navigation, Avionics and Flight Control
Robotics
Propulsion System and Unmanned Air Vehicle Subsystems
Telecommunications/Networking
Nuclear Technology
Sensors and Sensor Technology
Advanced Computer/Microelectronic Technology
Information Security/Encryption
Laser and Directed Energy Systems
Rocket Systems
Marine Technology
The following questions are to assess your country of chargeability for export control screening
purposes only. This information you provide will assist the Export Control Committee in the
review process and will not be used for any improper purpose.
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1. Name:
Department:
Email Address:
Office Phone:
Street Address:
City:
Home Phone:
State:
Country:
ZIP:
2. Are you a
Yes
Yes
Yes
Yes
No
No
No
No
Citizen or National of the United States.
Lawful Permanent Resident.
Refugee.
Person granted Asylum.
*** If your answer to any part of Question 2 above is “Yes,” please do not answer any of the
following questions. Rather, go directly to the Signature Section at the end of this page.
If your answer to any part of Question 2 is “No”, proceed to Question 3.
3. What is your place of birth?
Yes
No
Have you ever acquired citizenship, nationality, or permanent resident status in a
country other than your place of birth?
If “Yes”, please provide details (country(s), type of status, date of acquisition).
Comments
4. Yes
No
Have your ever relinquished, abandoned, or lost citizenship, nationality or
permanent residence in any country, including your country of birth?
If “Yes”, please provide details (country(s), status relinquished/abandoned/lost, and date of
relinquishment / abandonment/loss):
Comments
5. Please provide your Passport Number and issuing Country in the space provided.
Please submit a copy of your passport data page(s) to include photo and expiration date.
SIGNATURE SECTION
I understand WMU reserves the right to inquire further on any matter related to the University’s export
compliance obligations.
I certify that the foregoing answers are complete, true and correct to the best of my knowledge and belief.
Print Name:
Date:
Signature:
Date:
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6. PRINCIPAL INVESTIGATOR/CHAIR/DIRECTOR/DEAN OR ASSOCIATE DEAN:
With regards to any and all research projects the individual will have access to or work on,
please answer the questions below, attaching the project’s Scope of Work (SOW) and any
additional explanation if needed for answers to questions below. Based upon your answers,
you may or may not be asked to report follow-up export control reviews on a periodic basis.
Please mark each box below with a  following review of that section.
Category I: If the answer to any of these questions is “YES” please contact the WMU
Research Compliance Office at 1+ (269) 387-8293 immediately.
Yes
No
Does your proposed project(s) involve receipt or generation of classified information?
Comments
Yes
No
In your project(s), will you share, ship, transmit, transfer, or travel outside the U.S. with
WMU-developed, non-commercial encryption software in source code or object code form,
either stand-alone or embedded in other code?
Comments
Yes
No
Do you know or have any reason to believe that your project(s) will support
the design, development, production, stockpiling, detection, or use of a
nuclear explosive device, chemical or biological weapon, or missile?
Comments
Yes
No
Does any aspect of your project(s) potentially involve commerce with, travel to, or
shipment or payment to or from Cuba, Iran, North Korea, Sudan, or Syria?
Comments
Yes
No
Will your project(s) utilize a global positioning system (GPS technology)
outside of the United States, either for personal travel or as project equipment?
Comments
Category II – Please answer the following key question.
Yes
No
Is the purpose of your project(s) fundamental research that will predictably lead to
unrestricted publication in the open research literature? (If the answer is “NO”,
please indicate whether your project(s) is instruction, service / outreach,
testing, contract training, or something else.)
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Comments
Category III – Please answer the following supplemental questions.
Please provide explanatory comments for any “Yes” answer, attaching additional pages if needed.
Yes
No
Are you aware of any provision in your existing or proposed sponsored research
agreement (contract or grant) imposing publication restrictions beyond a brief
review (up to 90 days) for patent protection and/or inadvertent release of
non-WMU confidential or proprietary information?
Comments
Yes
No
Will any part of your project(s) be performed at a non-US academic site
(i.e., at a site that is neither an WMU site in the United States nor another
university site located within the United States)?
No
Will there be project participants who are not employees or students at a
university campus located in the United States?
No
As part of your project(s), are you or WMU being asked to sign a non-disclosure
or other confidentiality agreement regarding any WMU or non-WMU item,
information, data or software?
No
Did the funding for your project(s) originate or flow through a foreign government
or foreign governmental agency? If yes, please specify.
Comments
Yes
Comments
Yes
Comments
Yes
Comments
Yes
No
Does your project(s) require the delivery of a prototype or research samples
to the sponsor or another non-WMU party?
Comments
Yes
No
Is any article to be received for, used, or developed in your project(s)
a defense article on the ITAR’s U.S. Munitions List?
[see http://www.pmddtc.state.gov/regulations_laws/itar_consolidated.html]
[If you need assistance, please call 1+ (269) 387-8293].
Comments
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All other copies obsolete.
Yes
No
Is any information or software to be received for, used, or developed in your
project(s) technical data on the ITAR’s U.S. Munitions List?
Comments
If “YES”, is that information or software already (i) published, (ii) patented, or (iii) available via the
Web to all members of the public, free of charge, where WMU neither has knowledge nor exercises
control over who visits the Website or downloads the information? Where?
Comments
Yes
No
Did you, in your project(s) proposal, explicitly discuss military applications of your
project(s)?
Comments
Yes
No
In your project(s), are you receiving, shipping, or transferring items, technology,
software, or information on the EAR Commerce Control List?
[If you need assistance, please call 1+ (260) 387-8293.
To check the list, please see: http://www.access.gpo.gov/bis/ear/ear_data.html ]
Comments
If “YES”, is that information or software already (i) published, (ii) patented, or (iii) available via the
Web to all members of the public, free of charge, where WMU neither has knowledge nor
exercises control over who visits the Website or downloads the information? Where?
7. PROJECT TITLE OR EQUIPMENT NAME (IF APPLICABLE):
8. PROPOSED PROJECT DURATION:
From (mm/dd/yy):
To (mm/dd/yy):
9. FUNDING
Funding source: Select one
WMU proposal number for funded project:
Date of submission to funding agency:
10. SUMMARY OF WORK:
In language understandable to a layperson, summarize primary aims and describe the
individual’s research (scope of work) as concisely as possible.
Please provide a list of key words that will help the Export Control Committee classify
your technology/item.
Key words:
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CERTIFICATION/SIGNATURE
Projects potentially involving technology/information that is export-controlled under either the
State Department’s International Traffic in Arms Regulations (ITAR) or the Departments of
Commerce’s Export Administrations Regulations (EAR) must be screened by the Export Control
committee.
The information contained in this Export Control and Open Research Compliance Review
Worksheet and all required attachments are accurate to the best of my knowledge. All
personnel listed recognize their responsibility in complying with the University policies governing
the export control regulations. I declare that all research involving this individual will be
performed under my supervision.
If during the course of the research conducted by this individual, unanticipated events (in terms
of controlled technology security) occur, I will report them to the appropriate federal agency and
the Export Control Committee immediately.
Forward the Export Control and Open Research Compliance Review Worksheet to:
Research Compliance Coordinator
251 W Walwood Hall
Western Michigan University
1903 W Michigan Avenue
Kalamazoo, Michigan 49008-5456
You may sign, scan, and send as an email
attachment to:
research-compliance@wmich.edu
You may not proceed until the Export Control Committee has made its final
determination regarding the above-mentioned individual.
Furthermore, all future research projects involving this individual, that deviate
from the original scope of work, must be submitted to the Export Control
Committee for review before you may proceed.
Principal Investigator/Faculty/Host Name
Title
Principal Investigator/Faculty/Host Signature
Date
Print (Chair, Director, Dean or Associate Dean) Name
Title
Signature (Chair, Director, Dean or Associate Dean)
Date
Revised 03/28/2014 WMU Export Control ( S:\Compliance\Export Control\Application Forms)
All other copies obsolete.