Foreign Collaborations

Texas Tech University actively supports international collaborations that enhance global research, academic exchange, and innovation. However, partnerships with foreign individuals, institutions, or governments may be subject to U.S. export control laws, sanctions regulations, and institutional policy. The Office of Export and Security Compliance (OESC) provides compliance oversight and risk mitigation guidance for all international engagements.

When Is Export Control Review Required?

You must consult with OESC before initiating or formalizing a collaboration if:

• You are entering into a formal or informal agreement with a foreign individual or entity, regardless of whether funds are exchanged
• The collaborator is from an embargoed country (e.g., Cuba, Iran, North Korea, Syria, Crimea, Donetsk, or Luhansk regions of Ukraine)
• The collaboration involves restricted technology, unpublished research, or proprietary information not in the public domain
• You are participating in a foreign talent recruitment program, particularly one that may be considered malign under the CHIPS and Science Act of 2022
• The individual or institution appears on a Restricted Party List maintained by federal agencies such as the Department of Commerce, State, or Treasury

What Is Reviewed?

OESC will assess the proposed collaboration to determine:

• Whether the research qualifies as Fundamental Research under the EAR or ITAR
• Whether any export licenses, Technology Control Plans, or additional approvals are required
• Whether the collaboration poses a risk of undue foreign influence, unauthorized technology transfer, or potential violation of U.S. laws

Malign Foreign Talent Recruitment Programs

Under Section 10632 of the CHIPS and Science Act of 2022, malign foreign talent recruitment programs are defined as formal or informal efforts—typically sponsored by a country of concern (e.g., China, Iran, North Korea, or Russia)—to acquire U.S.-funded research or intellectual property in a manner inconsistent with academic integrity or U.S. law.

Indicators of malign programs may include:

• Undisclosed foreign compensation or dual appointments
• Agreements restricting disclosure or requiring allegiance to the sponsoring country
• Unauthorized transfer of intellectual property or confidential data
• Establishing labs or employment abroad without sponsor approval

Participation in such programs can render researchers ineligible for U.S. federal funding. If you believe you may be involved in a foreign recruitment program, contact OESC immediately for a confidential review and mitigation planning.

Restricted Party Screening (RPS)

Before initiating a collaboration, TTU must verify whether the individual or institution is listed on any federal Restricted Party Lists. These lists identify parties subject to sanctions, licensing requirements, or export prohibitions. A Restricted Party Screening (RPS) must be completed and documented for all international collaborators.

OESC uses a licensed compliance tool to conduct screenings and will notify you if additional steps are needed. You only need to screen a collaborator once unless circumstances change (e.g., new role, new institution, updated travel, or extended engagement).

Best Practices for Collaborators

• Consult OESC early: Contact us before finalizing agreements, hosting international partners, or disclosing proprietary information
• Avoid informal arrangements: All formal and informal agreements should be reviewed by TTU’s Office of Research Commercialization or Office of General Counsel
• Document all screenings and approvals: Keep records of Restricted Party Screenings, TCPs, and licensing decisions
• Maintain transparency: Fully disclose foreign affiliations, appointments, and funding in internal systems and federal disclosures

For questions or to request an export control review of your foreign collaboration, please contact the Office of Export and Security Compliance at exports.vpr@ttu.edu