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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Kevin Wozniak
Director, Research Security & Intellectual Property
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
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 provisions that clarify regulatory requirements and exclude low-risk academic activities from unnecessary co
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 crime controls and U.S. persons controls. AUECO expresses concern that the current definitions and pro
COGR Endorses AUECO Letter to U.S. Department of State on International Traffic in Arms Regulations: Revisions to Definition and Controls Related to Defense Services
The Association of University Export Control Officers (AUECO), supported by the Council on Government Relations (COGR), responds to the U.S. Department of State’s proposed revisions to the International Traffic in Arms Regulations (ITAR) related to defense services. AUECO generally welcomes the increased clarity and reduction of redundancies in the definitions and controls, noting that such change
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
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 members of COGR’s four committees.
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 open science and international collaboration, but balances this with emerging national security
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 congressional mandate under the Chips and Science Act (Public Law 117-167), aims to provide a compreh
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
