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Research Security at UW

UW is required by the to have an integrated program for research security.  The UW Research Security program comprises various components which, together, fulfill federal legal and regulatory requirements.  While the program centers on research, it applies to all university activities.

Content


Export Control Regulations

Sharing controlled items and information with a foreign national as well as shipping-controlled items to a foreign destination may require export licensing. There are some export license exceptions.

Primary responsibility for compliance with export regulations falls on the Principal Investigator. The following activities may be subject to export control regulations, and can occur at any time during your research:

  • Sharing proprietary or otherwise restricted information, technology or software with a foreign national
  • Engaging in a sponsored project where the research results must be approved by the sponsor prior to publication
  • Projects performed abroad by UW personnel
  • Export of tangible items outside the United States
  • Furnishing defense services to a foreign person or entity within the United States or abroad
  • Transacting with embargoed or sanctioned countries or parties

More information about these activities can be found on the Export Controls webpage.


International Travel

Federal regulations require the University, as a “covered institution” receiving federal science and engineering support in excess of $50 million per year to register international travel of covered individuals and ensure covered individuals receive foreign travel security training. The University must establish and operate a research security program that includes an organizational record of international travel as a component of a travel reporting program.

Registering Official International Travel

All personnel, including staff, faculty and other academic personnel, and students, involved in UW research are required to register all international travel for in the UW International Travel Registry

Registering Personal International Travel

All Covered Individuals are required to register all personal international travel for teaching, research, or conferences (attending or presenting) in the UW International Travel Registry.

Foreign Travel Security Training

The University must implement periodic training on foreign travel security to Covered Individuals initially and at least every six years. All personnel, including staff, faculty and other academic personnel, and students, involved in UW research are required to complete this training. Please note: This training is currently in development.


International Activities Assessment Process

The Ƶ is committed to international collaborative research and academic activities. The caliber of our researchers and students make the UW a leader in quality and impact. However, some international activities expose the UW community to substantial risks and may interfere with the University’s mission or infringe upon our culture of academic freedom. Activities associated with increased legal, reputational, or financial risk require an additional review.

International Activities Assessment Process Criteria

The International Activity Assessment Process is required when UW activity, such as an agreement or transaction, includes involvement by a party or entity:

  1. Associated with one or more of the following countries of concern:
    • China, including Hong Kong and Macau
    • Iran
    • North Korea
    • Russia
    • Crimea and the “Covered Regions” of Russian-occupied Ukraine (Donetsk and Luhansk)
    • Belarus
    • Cuba
    • Venezuela

or

  1. is a foreign military, intelligence, security, or police organization; or a research organization affiliated with a foreign military, intelligence, security, or police organization (even if not associated with a country of concern).

Involvement means that a party to the activity is any of the following (not exhaustive list):

  • Is a funder (e.g. sponsor, donor)
  • Will participate on a sponsored project or other research with UW
  • Is considered a foreign component
  • Will receive or share information, data, technology, material or other tangibles or non-tangibles
  • Will be a customer, vendor, or otherwise enter an agreement with the University

Involvement by an international Ƶ enrolled student, undergraduate or graduate level, does not qualify for this assessment process while at UW. However, UW students and postdocs who independently collaborate with or sign an agreement with international parties that meet the above criteria must inform their mentor and follow the assessment process.

International Activities Assessment Process

  • Business or Academic Unit runs Restricted Party Screening on the international entit(ies).
  • Business or Academic Unit completes the .
    • The form is reviewed initially by the Research Security Office (RSO) and Export Controls Office (ECO) in the Office of Research.
    • Initial Review consists of reviewing restricted party screening results, export control review, as applicable, and potential follow-up with the Business or Academic Unit about mitigations.
      • If this review indicates that this is not a high-risk research activity or that risk can be managed with specific mitigations, the RSO will notify the Business or Academic unit that they can proceed.
      • If this review indicates the University may not proceed, as it will be in violation of federal law, regulation or sponsor policies, and not eligible for an exception or license, the RSO will contact the Business or Academic Unit.
      • If the initial review indicates that further assessment is needed, it will be escalated to the Chair of the International Activities Committee (Assistant Vice Provost, Research Compliance and Administration).
  • The Chair will determine whether the requested activity needs full Committee review and communicate with the Business or Academic Unit.
  • All assessment records are maintained by the Office of Research.

The International Activities Committee includes leadership from the Office of Research, Office of Global Affairs, UW Innovation, Corporate & Foundation Relations, Finance, and the Chief Information Security Officer.

Recommendations of the International Activities Committee are advisory to the President and Provost.


Compliance, Disclosures, and Reporting

The University as well as individual UW researchers are required to make certain certifications regarding compliance with federal research security regulations.  Non-compliance or falsely certifying compliance presents individual and institutional risks.

Disclosures and Reporting

The University as well as individual UW researchers are required to report certain financial and other support from, and collaborations with, international entities.

Institutional Reporting

  • Section 117 of the Higher Education Act of 1965 requires the University to report all gifts and contracts received from a foreign source that amount to $250,000 or more in a calendar year.
  • Section 10339B of the CHIPS & Science Act requires the University to report all financial support received from a source associated with a Foreign Country of Concern that amounts to $50,000 or more.

Individual Researcher Disclosures and Reporting

Malign Foreign Talent Recruitment Programs (MFTRPs)

In accordance with the CHIPS and Science Act of 2022, all faculty, staff and other University personnel are prohibited from participating in malign foreign talent recruitment programs (MFTRPs), detailed in the July 2024 Presidential Memorandum. Further information about MFTRPs can be found on the Foreign Interests in Sponsored Programs.

Critical and Emerging Technologies List

Critical and Emerging Technologies are a subset of advanced technologies that are potentially significant to U S national security. Though not a strategy document, may inform government-wide and agency-specific efforts concerning U S technological competitiveness and national security. Research in these and related areas may be subject to existing and developing federal regulation and monitoring.


Restricted Parties

The University engages and transacts with many parties, including consultants, customers, and others who carry out work, research, or provide goods and services to UW.

Restricted Party Screening (RPS) is a step the University carries out to prevent the unauthorized transfer of sensitive technologies and materials, play a part in economic & national security efforts, and minimize other risks to the institution.

RPS is the review of institutions and individuals against restricted party lists maintained by government agencies, international organizations, and regulatory bodies to identify threats to national security, export regulations, and trade sanctions.

By performing RPS, the University can continue to responsibly lead in innovations and scientific advancement.

Restricted Party Screening Process

The Ƶ maintains a subscription to Descartes™ Visual Compliance software that searches federal restricted party lists, automatically updates as changes to the lists occur, and notifies UW of potential matches.

UW personnel who will conduct RPS in their area of responsibility must .

  • Review the Restricted Party Screening “How-To” guidance
  • Any alerts generated by RPS should be evaluated by the responsible business unit for a false positive result.
  • Once a match is confirmed, the unit must then assess the risk.
    • If the activity may not proceed, based on screening results, document your search, and why the activity may not proceed and communicate the decision with the business or academic unit head and impacted individual(s).
    • If you think the activity could proceed but it is associated with a country of concern or an entity considered a foreign military, intelligence, security, or police organization affiliated with such an organization please use the International Activities Assessment Process, which requires attaching your RPS results.

If there are any questions on screening, or your unit needs training on how to screen, contact researchsecurity@uw.edu for further guidance. This applies to all UW units and activities.

When to Screen

Restricted Party Screening should occur across the University, and prior to these activities involving an international nexus and/or a foreign party:

  • Research collaborations (including unfunded collaborations)
  • Sharing UW information, materials or data, including licensing IP
  • Affiliate appointment
  • Providing editing or informal peer-review of an unpublished publication
  • Providing goods or services under
  • Procurement of goods or services
  • Official travel
  • Licensing of UW intellectual property
  • Educational exchange programs
  • Hosting visitors
  • Exports: deemed and/or physical
  • Accepting funding (gifts, donations, research support, etc.)
  • Invited presentations, awards associated with presentation requirements

Information Security and Privacy

Privacy protections for individuals whose personal information is collected or otherwise used in research apply to all UW research and are considered integral to overall research security.

  • The , within UWIT, provides information about UW data and information privacy.
  • The provides comprehensive information on the University’s institutional approach to information security.
  • General guidance on information/data security and privacy in research, covering topics including CUI (Controlled Unclassified Information), requirements for human subjects research, EU GDPR (European Union General Data Protection Regulation), and classified information may be found here.

Research Security Training

Federal research sponsors, such as NSF and DOE, require completion of Research Security Training by all “covered individuals” participating on a project before an application for funding is submitted as of May 25 2025. The definition of covered individual varies by federal agency. Generally, however, it refers to “an individual who (A) contributes in a substantive, meaningful way to the scientific development or execution of an R&D project proposed to be carried out with an… award from a Federal research agency; and (B) is designated as a covered individual by the Federal research agency concerned.” See the

The USDA requires all individuals employed to work on a USDA award to complete Research Security Training (see .

Currently, research project-specific training in Export Controls, a component of Research Security, is required for certain activities. The UW Office of Export Controls is available to provide guidance as well as training, where it is required.

FAQs

More information about Research Security training can be found in these FAQs.

Enrollment

If you are the PI of an impacted proposal, ensure all covered individuals have completed training ahead of the anticipated submission date. This research security training requirement can be met by completing the CITI-hosted training.

Research Security Training Verification

Completion of Research Security Training will be reflected in MyResearch Training Transcript (MRTT). Completion records in MRTT will be linked for each individual listed on the PI, Personnel and Organizations page of the eGC1.  Campus units can use these links to verify covered individuals have completed training.

The Office of Sponsored Programs will verify that individuals named in federal proposals have completed training in alignment with sponsor policies.


Research Security by Role

As a Researcher, your role carries with it responsibilities for research security.  If you are the Principal Investigator (PI), you are also responsible for overall compliance of the project (and its associated personnel) with research security regulations.

Checklist

If your project/lab/research group involves any of the following, research security regulations apply

  • A Critical or Emerging Technology
  • Employment or hosting of non-U S persons, including students, postdoctoral scholars, visiting scientists, or other visitors
  • Work done in an international location
  • Funding from an international source
  • An international collaborator
  • Data or materials shared with, or obtained from, an international source

As a Research Administrator, your role carries with it responsibilities for research security.  Depending upon the duties of your position, you may be responsible for ensuring compliance by identifying, tracking, and/or reporting specific research security components applicable to a research project or lab.  Working with the PI and project or lab personnel, you can facilitate compliance by understanding research security policies, regulations and best practices and assisting in their application.

Checklist

If your project/lab/research group involves any of the following, research security regulations apply:

  • A Critical or Emerging Technology
  • Employment or hosting of non-U S persons, including students, postdoctoral scholars, visiting scientists, or other visitors
  • Work done in an international location
  • Funding from an international source
  • An international collaborator
  • Data or materials shared with, or obtained from, an international source

As staff to a research project or lab, your role carries with it responsibilities for research security.  You are responsible for understanding research security policies, regulations and best practices as they apply to your work and to the work of those you supervise.

Depending upon the duties of your position, you may also have an administrative role in ensuring compliance by identifying, tracking, and/or reporting specific research security components applicable to a research project or lab.  If so, working with the PI and project or lab personnel, you can facilitate compliance by understanding and assisting in their application.

Checklist

If your PI’s project/lab/research group involves any of the following, research security regulations apply:

  • A Critical or Emerging Technology
  • Employment or hosting of non-U S persons, including students, postdoctoral scholars, visiting scientists, or other visitors
  • Work done in an international location
  • Funding from an international source
  • An international collaborator
  • Data or materials shared with, or obtained from, an international source

As an undergraduate student, graduate student or postdoctoral scholar working on a research project, your role carries with it responsibilities for research security.  You are responsible for understanding research security policies, regulations and best practices as they apply to your work and to the work of those you supervise.

Checklist

If the project you are working on or the lab/research group in which you are working involves any of the following, research security regulations may apply:

  • A Critical or Emerging Technology
  • Employment or hosting of non-U S persons, including students, postdoctoral scholars, visiting scientists, or other visitors
  • Work done in an international location
  • Funding from an international source
  • An international collaborator
  • Data or materials shared with, or obtained from, an international source

Research Security by Design

The Ƶ aims to provide a research security focused culture while maintaining an open-research environment. Research Security by Design is a resource developed by The UW Office of Sponsored Programs to help build research security into a UW research program.


Contact

Email researchsecurity@uw.edu to:

  • Request a consultation
  • Request research security information
  • Report non-compliance
  • Check the status of a program activity
  • View employment opportunities

The Chief Research Security Officer is UW’s designated single point of contact for communications with the federal government on matters involving Research Security. Contact the Chief Research Security Officer, Jasmine Campbell, at jlnc@uw.edu.