COGR, together with AAU and APLU, submitted joint comments to the Bureau of Industry and Security (BIS) on its interim final rule, which expands end-user controls to...
Export Controls
Balancing the need to protect national security and economic interests with the open, collaborative nature of higher education can be challenging in sensitive technology areas subject to export control regulations.
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COGR Submits Response to Interim Final Rule—“Implementation of Controls on Advanced Technologies Consistent with Controls Implemented by International Partners”
COGR submitted a formal response to the U.S. Department of Commerce Bureau of Industry and Security's interim final rule regarding the implementation of export...
COGR Endorses AUECO Comments to BIS on End-Use and End-User Based Export Controls, Including U.S. Persons Activities Controls: Military and Intelligence End Use and End Users
The Association of University Export Control Officers (AUECO) submitted comments regarding the U.S. Department of Commerce’s proposed amendments to export controls...
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All Export Controls Articles
COGR, AAU, and APLU Submit Joint Comments on BIS Interim Final Rule (RIN 0694-AK11)
COGR, together with AAU and APLU, submitted joint comments to the Bureau of Industry and Security (BIS) on its interim final rule, which expands end-user controls to affiliates of certain entities. The associations highlight that the rule, as written, could create substantial and ambiguous compliance burdens for universities and potentially stifle legitimate international research collaborations.
COGR Submits Response to Interim Final Rule—“Implementation of Controls on Advanced Technologies Consistent with Controls Implemented by International Partners”
COGR submitted a formal response to the U.S. Department of Commerce Bureau of Industry and Security's interim final rule regarding the implementation of export controls on advanced technologies. COGR acknowledges the necessity of safeguarding sensitive technologies amid evolving global threats and supports efforts to align U.S. regulations with those of international partners, while also emphasizi
Overview of OSTP Guidelines for Research Security Programs at Covered Institutions
The OSTP Research Security Program Guidelines, released July 9, 2024, establish four required elements for research security compliance—cybersecurity, foreign travel security, research security training, and export control training—at institutions exceeding a $50 million annual federal R&D threshold, with detailed timetables for agency and institutional implementation. The Guidelines promote u
Restrictions on Research Awards: Troublesome Clauses. A Report of the AAU/COGR Task Force
The AAU/COGR Task Force report examines the growing prevalence and impact of restrictive clauses—termed “troublesome clauses”—in U.S. research awards, particularly those that limit the dissemination of research findings or the participation of foreign nationals without prior approval. Despite the long-standing federal policy articulated in National Security Decision Directive 189 (NSDD 189)—which
Restrictions on Research Awards: Troublesome Clauses 2007/2008
This report, produced collaboratively by the Council on Governmental Relations (COGR), the Association of American Universities (AAU), and the Federal Demonstration Partnership (FDP), addresses the growing prevalence and complexity of restrictive clauses in federal research awards to U.S. universities. These "troublesome clauses" often limit the publication of research findings and restr
Troublesome Clauses in Research Awards
The document outlines several problematic contractual clauses related to information release and the employment of foreign nationals in federally funded research agreements, particularly those involving the Department of Defense and other federal agencies. These clauses often require burdensome review and approval processes prior to the public release of unclassified research results, restrict the
