Compliance

Export Control & Research Security

Export Control

The term "export controls" refers to a set of federal laws and regulations. These laws and regulations are used to restrict both physical and nonphysical exports of items that could contribute to the military potential of international adversaries, to advance U.S. foreign policy goals, and to protect the U.S. economy and promote trade goals.  Violations of export control regulations can result in severe monetary penalties and sanctions for the SIU System as an institution as well as individual PIs and administrators. For questions, contact the SIU Export Controls Office.

Please see SIU’s Policy on Export Control and the SIU Export Control webpage.  Note the following available resources.

• Vulnerabilities of campus groups to influence
• Responses to suspicious activities
• Proactive behaviors for travelers
• Situational awareness and prevention tips
• Travel security, cyber security, and counterintelligence resources
• Malign Foreign Talent Recruitment Program (MFTRP)

*Please note: Mandatory export control training shall occur, at a minimum, every (3) years and is managed by the Export Controls Office (SIU Export Control Policy). For more information on required training,  please contact the SIU Export Control Office. 

All SIUE faculty and staff traveling to any of the countries listed below must use the SIU Clean Laptop Program.

Research Security

Similar to export control, research security is a form of national security. Since 2021, both the executive and legislative branches have issued regulatory measures to address growing global security concerns. The regulatory measures directly affecting universities are found in National Security Presidential Memorandum-33 (NSPM-33) and the CHIPS and Science Act (CHIPS). NSPM-33 requires all federal research funding agencies to strengthen and standardize disclosure requirements for Universities and researchers receiving federally funded awards. CHIPS requires:

• Researchers on federal research awards to complete annual research security training. (Section 10634)
• Researchers to certify at the time of proposal submission and annually during the duration of an award that they are not part of a malign foreign talent recruitment program. (Section 10632)
• Institutions to certify that researchers are aware of the prohibition of participating in malign foreign talent recruitment programs. (Section 10634)

Guidance on Specific Sponsor Research Security Requirements 

Within 2025, the federal government will begin requiring research security training of covered individuals, as defined by each federal agency, prior to submitting proposals for federal awards. The Department of Energy (DOE) is the first agency to release their research security training requirement effective May 1, 2025.

DOE

Who: Covered Individuals - At a minimum, DOE designates as covered individuals any PI, PD, Co-PI, Co-PD, project manager and any individual regardless of title that is functionally performing as PI, PD, Co-PI, Co-PD or project manager.  DOE may expand who qualifies as a covered individual in the Notice of Funding Opportunity(NOFO). See definition of Covered Individual here. Status as a consultant, graduate (master's or PhD) student, or postdoctoral associate does not automatically disqualify a person from being designated as a "covered individual". 

What: Covered individuals must certify they have completed research security training within one year of application date. DOE interprets this as the 12 months immediately preceding the application date. See DOE's Research Security Training Requirements for all R&D Financial Assistance Awards located here.

CITI Research Security Training

Researchers have three research security training options through the online CITI Program:

• "Research Security Training (Combined Course)" - A condensed and combined single module course based on the NSF Research Security Training.
• "Research Security Training" - Comprehensive four module course supported by funding from NSF, NIH, DOE and DOD.
• "Research Security Advanced Refresher" - Provides foundational information and explores advanced research security topics.

Please see the SIUE Compliance Education page for research security and other compliance training information and links.