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Every Institution Needs an Up-do-Date Export Controls Program

By SRAI News posted 03-09-2023 09:35 AM


Every Institution Needs an Up-do-Date Export Controls Program

As a champion of free thought and education, US college campuses allow sharing knowledge, the dissemination of ideas, and provide opportunities for students from around the world to work on cutting edge technologies and discoveries. They also allow open discussions and debates by students and faculty. These are good things for foreign intelligence services too. Here, they can find students with particular political or ideological beliefs by attending campus rallies that are open to public and interacting with particular student clubs or reading campus newspapers and blogs. When they discover someone they think will help their cause, next they may approach that person and entice him/her to join their cause. Foreign intelligence services may use a variety of enticements to recruit people such as money, blackmail, revenge, all-expense paid trips, and flattery, for example. They support the students or staff to share the classified information with those not authorized to receive it.

In recent years, institutions of higher education have been directly targeted by recruiting staff and faculty members via Thousand Talents and other similar programs. Read more about the Chinese Talent Program here, and peruse this database to understand the history and scope of these types of programs. To be clear, there are many countries that offer the talents program and each one of these needs to be carefully evaluated.

To mitigate the harm to our national interests, the export of certain items and information is regulated for reasons of nation security, foreign policy, prevention of the spread of weapons of mass destruction, and for competitive trade reasons, in accordance with United States laws and regulations. Export Controls Compliance is everyone’s responsibility, and non-compliance has severe implications for an entire institution. 

In order to help colleges and universities understand and mitigate risks by developing a robust Export Controls Program, the Federal Bureau of Investigation (FBI) offers free outreach to all institutions of higher education. The federal bodies regulating the funded research are complexly interconnected and the agencies put out several lists. The red flag list produced by these agencies identifies individuals, companies, and even countries with different levels of sanctions and embargoes. All institutions of higher education can invite an agent, speaker for the campus by writing to the agency. The agents have education in the subject area and have many years of field experience to offer guidance.

Authored by Rani Muthukrishnan, Director, Research Compliance
Texas A&M University, San Antonio