Export controls govern:
- Works generated using Miami resources as well as when funded personally and/or through externally funded grant and contract dollars.
- Regardless of whether an employee is under contract at the time of engagement.
Research Security
Miami University values international collaboration and assists faculty, staff, and students to remain compliant with US export controls that govern these collaborations.
Per US export controls, Miami University students and employees may be restricted in engagement with certain entities (e.g., companies, institutions of higher education, persons, countries).
- In almost all instances, a management plan can be implemented where research and other activities can proceed within specified guardrails.
Collaboration is recognized as critical in many research efforts
- Registering collaborations helps ORI to help you ensure that collaborations do not violate research security regulations.
- Our goal is the continued success of Miami researchers.
- Non-compliance can jeopardize national security and invoke significant individual and institutional penalties.
The associated Miami policy can be located here.
- Of note, the policy applies in instances such as when you are serving in your faculty appointment (such as serving on a graduate committee), paying personally for travel to a conference where you register as a Miami employee, taking Miami-owned property, doing personal travel before and/or after travel related to Miami employment, invited to participate because of your role as a Miami employee.
Please select one of the options below to complete an International Travel or Collaboration request
ORI will use the IPTalons Certified Secure Researcher platform and prepare Research Security Screening Reports
- These are similar to a credit report
- It is a view from the perspective of a funder or institution of “how much risk does a person’s research portfolio present?”
- Examines risk based on existing collaborations and publications
ORI will examine Faculty and Staff risk profiles
- Contextualize the foreign collaborative profile compared to federal research security mandates
- Evaluate Foreign Influence Group (FIG) collaborations
- Compare collaborations to Sanctions & Export Control restrictions
ORI will meet with the Faculty and Staff with the highest personal and institutional risk
- This will follow the proposed Risk-Informed Collaboration Evaluations process
Please complete the form below for any (non-student) international travel at least one month before departure. Travel is not to be undertaken prior to receiving approval through ORI.
Please be aware, "The Fly America Act (49 U.S.C. 40118) requires that all air travel funded by the U.S. federal government (grants, contracts, or federal funds) must use U.S. flag air carriers, regardless of cost or convenience. Compliance mandates booking with an American-owned airline, or using a foreign carrier via a code-share agreement, for international travel to, from, or between foreign countries." Costs for flights on foreign carriers that do not meet exceptions may be disallowed.
- Please note, multiple trips can be listed in one request.
- Review can take up to 10 - 15 business days.
- You are required to make your direct supervisor aware of your international travel.
Employees:
Please complete the form below for international travel when undertaking any Miami University employment responsibilities and/or when taking a Miami-issued laptop (or other equipment).
Undergraduate and Graduate Students:
If you are not working through the Miami travel abroad program but instead are traveling for purposes such as research or to a professional conference, use the link below to register the travel. Await approval before traveling.
For international travelers, please contact Cheryl Young (youngcd@MiamioOH.edu), coordinator for Global Health and Safety at Miami, who will provide the additional guidance for your travel.
Training
The online course (CITI Program) is composed of modules about research ethics, policies, regulations, and safety. Each module is completed by taking a quiz.
Initial Training
There are two required modules for Export Compliance (EC). There are an additional ten modules that are specialized and may be relevant to your activities and required for you to complete by the export compliance coordinator, e.g. EC and Biosafety.
Refresher Training
Three years after initial training and every three years henceforth if still engaged in activities that might be impacted by EC regulations, you will be required to complete Refresher Modules (the number of modules depends on how recently you completed the original training and how the regulations and your activities have changed).
Senate Bill 1 took effect in 2025, prohibiting Chinese Government funding
- No state institution of higher education shall accept gifts, donations, or contributions from the People's Republic of China or any organization the institution reasonably suspects is acting on behalf of the People's Republic of China.
- Prohibited engagement with certain entities
- Entities can include
- persons
- academic institutions
- governments
- companies
- other entities
- A full description of the legislation can be found here
- When you register collaboration, ORI can help identify and guide on what is allowable
- Both are programs of foreign governments to recruit
- Scientists, engineers, academics, researchers, and entrepreneurs working or educated in the US
- Compensation through
- Honorific title or position, Cash
- Access to resources, Research funding
- Promised future compensation
- Complimentary foreign travel
Malign Foreign Talent Recruitment Program (MFTRP)
- Attempt to acquire U.S. scientific-funded research or technology unethically or unlawfully
- May appear as an honor, as a funding source, as a request for your research expertise, etc.
- Illegitimate goal may not be articulated to you
How do you know if it is an MFTRP?
Indicators of Malign Foreign Talent Recruitment Program:
- Participants are required by the talent program to engage in unauthorized transfer of intellectual property, materials, data products, or other nonpublic information
- This is one reason for ensuring a material transfer agreement (MTA), and data use agreement (DUA) are in place
- Participants are required to recruit trainees or researchers to participate in the program or activity
- Participants are required to establish a lab or company or to accept a faculty position/employment in violation of standard terms and conditions of a federal award
- Participants are disallowed from terminating the contract except in extraordinary circumstances
- Please, ask ORI for help in discerning
- If you receive a recruiting email, please forward to ORI
- Participants are required by talent program to commitments that limit the capacity to carry out a U.S. federal award or would result in substantial overlap or duplication
- Participants are required to apply for or successfully receive funding from the sponsoring foreign government’s funding agencies, with the foreign organization as the recipient
- Participants are required to omit acknowledgement of the recipient institution (i.e., Miami University), or the U.S. federal research agency sponsor
- Participants are required to withhold information about participation in the program and not to disclose it to the U.S. funding agency or to Miami University
What to do if you are or if in your past you or a collaborator were in MFTRP?
- If you ever were in an MFTRP for Talent Program and/or if you still are in either program
- Contact ORI
- Provides documentation of MU awareness
- Provides guidance
- Contact ORI
How the programs impact grant funding
- MFTRP - All federally funded researchers are prohibited from participating in malign foreign talent recruitment programs
- Talent Program - May constitute a conflict of commitment and/or a significant financial conflict of interest. Please disclose all foreign sources of support at time of funding proposal
- NIH
- If a researcher is currently in a Malign Foreign Talent Recruitment Program (MFTRP) they are not eligible to serve as a senior/key person on an NIH grant or cooperative agreement.
- If subrecipient is a foreign entity, these are now completed as direct foreign awards (instead of as subrecipient agreements)
- NSF
- Changest the time of proposal, at time of updating current and pending, and annually self-certify MFTRP status
When inviting scholar to Miami for a lecture, as a volunteer, as a J-1 Scholar, in any capacity:
- At least 15 days prior:
- Fill out application at Global Initiatives website if for short term visitor or J-1 Scholar
- Contact Global Initiatives for any other scenario
- Contact grant manager if work/travel is charged to a grant or contract
Prior to sending OR receiving any materials, technology, or data
- with U.S. person or with non-U.S. person
- inside or outside the U.S.
- by electronic transmission (such as email)
- by hand-delivery
- by shipment (via Miami or personally)
- to or from anyone in research group
- at time of move to Miami or at any other time
- in the form of digital, cloud-based, physical, or any type of material (biological, chemical, component, etc.)
- through purchase outside Miami Procurement (such as on your behalf by a friend/colleague)
Materials where an MTA is needed
- any Miami property that is not being sent to a vendor for fee-for-service work. Includes, but is not limited to:
- cell lines
- plasmids
- nucleotides
- proteins
- transgenic animals (such as mice, rats, fish, etc.)
- tissues (plant, animal)
- plant varieties
- bacteria
- pharmaceuticals
- other chemicals
- geological samples
Shipping of Materials
- Ship only through your department
- No PI to ship individually
- Do not use a shipper outside of Miami process
When is a DUA needed?
- Data are proprietary
- No plan to disseminate (to publish) the work
- Federal or state statutes limit dissemination
- Funding sponsor limits dissemination
Do not sign NDA, MTA or DUA – send to ORI
- Wesley Wright
- Send to origrants@miamioh.edu
- If you are aware of an area where an MTA should have been in place already, where a collaboration should already have been registered, or any circumstance just reach out now and we will assist
Research Security:
Visiting Scholars and International Travel
Material Transfer Agreements (MTAs), Data Use Agreements (DUAs) and Non-Disclosure Agreements (NDAs):
- Sue McDowell (mcdowes2@miamioh.edu) until June 30, 2026
- Rick Page (pagerc@miamioh.edu)
Visiting Scholars and International Travel
- Molly Heidemann (heidemml@miamioh.edu)
- Cheryl Young (youngcd@miamioh.edu)
Material Transfer Agreements (MTAs), Data Use Agreements (DUAs) and Non-Disclosure Agreements (NDAs):
- origrants@miamioh.edu
- Wesley Wright (but please use the entity account origrants@miamioh.edu for emailing)
CITI training modules may be of great help to you and your research group
- Use Miami log-in
Office of Research and Innovation
102 Roudebush Hall
501 E. High St.
Oxford, OH 45056