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Comment Letter

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...

Comment Letter

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...

External Resource

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...

Resources

Comment Letter 31 Oct, 2025

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…

Comment Letter 05 Nov, 2024

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…

External Resource 30 Sep, 2024

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 on end-use and end-user activities, particularly those relating to military and intelligence applications. While AUECO welcomed…

External Resource 30 Sep, 2024

COGR Endorses AUECO Comment Letter to BIS on Export Administration Regulations: Crime Controls and Expansion/Update of U.S. Persons Controls

The Association of University Export Control Officers (AUECO), representing over 500 compliance professionals at more than 200 U.S. higher education institutions, submitted comments regarding the U.S. Department of Commerce’s proposed amendments to the Export Administration Regulations related to…

Event Materials 29 Sep, 2023

Session Materials Available: Workshop on Compliance with Research Security Requirements and the Associated Cost of Compliance Survey

On September 27, 2023, COGR hosted a virtual, interactive workshop to provide an opportunity for members to share information on institutional efforts to comply with research security requirements and how to assess associated costs and institutional burden. The workshop was led by COGR directors and...

Matrices & Trackers 20 Sep, 2023

Policy for Risk-Based Security Reviews of Fundamental Research

The document outlines the Department of Defense's (DoD) comprehensive policy for risk-based security reviews of fundamental research, particularly as conducted by academic institutions. In the context of maintaining U.S. dominance in science and technology, the DoD recognizes the critical value of…

External Resource 12 Apr, 2023

Follow-Up from Zoom Meeting with BIS Representatives re. the Civil Space Industrial Base (CSIB) Survey and Assessment

The document is a follow-up communication from COGR Member Services summarizing key points discussed during a Zoom meeting with representatives from the Bureau of Industry and Security (BIS) regarding the Civil Space Industrial Base (CSIB) Survey and Assessment. The CSIB survey, prompted by a NASA…

Policy Perspective 15 Jan, 2021

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…

Policy Perspective 14 Jan, 2021

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…

Comment Letter 05 Nov, 2020

Joint Association Comment Letter Regarding Foundational Technologies ANPRM

This letter contains joint association comments regarding concerns associated with potential expansion of controls on foundational technologies.

Event Materials 26 Oct, 2020

Research Security and Intellectual Property Hot Topics: October 2020 Meeting

The document is a comprehensive overview of key issues on research security and intellectual property management discussed during a panel convened by the Council on Governmental Relations (COGR) on October 22, 2020, featuring experts from leading research universities. The panelists addressed…

Event Materials 18 Aug, 2020

Foreign Influence and Research Security: The Challenges Continue Webinar Slides Now Available

The document summarizes a panel discussion on ongoing challenges related to foreign influence and research security in the U.S. research enterprise, with contributions from senior representatives of government agencies, academic associations, and universities. Key topics include updates from the…

Event Materials 03 Mar, 2020

RSIP Committee Report: March 2020 Meeting

The document provides an update on several key initiatives and regulatory changes impacting research security and intellectual property management, primarily within the context of federally funded research in the United States. It outlines the ongoing redevelopment of the iEdison system, which…

Event Materials 10 Jun, 2019

Contracts & Intellectual Property Update: June 2019 Meeting

The document outlines recent developments and ongoing discussions concerning contracts and intellectual property at U.S. academic and research institutions, with a particular focus on the influence of foreign entities. It details the increasing scrutiny from legislative and federal agencies…

Policy Perspective 11 Jan, 2019

Joint Association Comment Letter on Emerging Technologies ANPRM

This letter contains joint association comments in response to the Advance Notice of Proposed Rulemaking Regarding Review of Controls for Certain Emerging Technologies Reference: 83 Fed. Reg. 58201 (Nov. 19, 2018).

Comment Letter 04 Dec, 2018

Joint Association Memo Requesting Extension from BIS

This letter contains a joint association request for an extension to provide comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) on the “Review of Controls for Certain Emerging Technologies published by the Bureau of Industry and Security (BIS) in the Federal Register on...

Archived 17 Jul, 2017

COGR Submits Joint Association Letter on DOE Regulatory Reform

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.”

External Resource 08 Aug, 2016

National Security Decision Directive 189

NSDD Directive 189, issued on September 21, 1985, outlines the United States national policy regarding the dissemination of scientific, technical, and engineering information derived from federally funded fundamental research at academic and research institutions. The directive defines fundamental…

External Resource 08 Aug, 2016

Letter from National Security Advisor to CSIS

This is a copy of a letter from Dr. Rice, National Security Advisor to the President in response to a letter from COGR on the Future of Technology and Public Policy regarding export controls and fundamental research.

Policy Perspective 08 Aug, 2016

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…

Policy Perspective 08 Aug, 2016

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…

Policy Perspective 08 Aug, 2016

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…

Policy Perspective 08 Aug, 2016

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…

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