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Miami University values international collaboration and assists faculty, staff, and students to remain compliant with US export controls that govern these collaborations.

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.

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.

Forms

Please select one of the options below to complete an International Travel or Collaboration request

Collaboration

Please complete the form below for collaboration at least one month before your expected collaboration. Collaboration is not to be undertaken prior to receiving approval through ORI.

The term “collaboration” includes such activities as sharing of information (such as proprietary information, intellectual property, unpublished results, inventions not yet patent protected, etc), data, measurements, instrumentation, know-how, etc., verbally, through electronic communication, or any other means, performing any measurements or procedures, or undertaking any review, editing, writing or analysis toward publication. The term “collaborator” includes undergraduate and graduate students at any institution, Miami University employees, and any other US or Non-US Person inside or outside the United States (no need to ask collaborator whether they are Non-US, ORI can find this information if needed). 

  • Please note, multiple collaborators can be listed in one request. 
  • Review can take up to 10 - 15 business days.
  • Disclosure is required for all collaborations.
  • If you are planning to bring an international scholar to campus, please ensure you have submitted both the Collaboration Form (below) and the J-1 Scholar Form for review.

Collaboration

International Travel

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. 

International Travel

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).

FAQs

Senate Bill 1 Compliance

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

Malign Foreign Talent Recruitment Program (MFTRP) vs. Talent Program

  • 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

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 
Additional changes in federal requirements 
  • 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

Definition of Collaborator

Individuals undertaking the collaboration, including:

  • Undergraduate and graduate students at Miami or any institution 
  • Miami University employees, 
  • Any other US or Non-US Person 
    • Please do not ask collaborator whether they are Non-US
  • Inside or outside the United States
  • All co-authors on manuscript if you are the corresponding author
  • Note - registration should be at the initiation of each collaboration – not at time of publication 

When to register collaborations 

  • Prior to engaging in collaboration
  • If a collaboration was on-going until you learned of the requirement
    • Enables research security plan to be implemented if needed
    • Provides documentation your collaboration was reviewed
  • Register through portal located on this page under the forms section
    • Can provide CV and or ORCID of collaborators rather than list

What happens after you submit materials/information?

ORI reviews your request and submits the information to our consultant, IPTalons for review.
  • IPTalons (Miami's research security consulting firm)
    • Screens for
      • Entity List 
        • Individuals, companies, institutions, under federal prohibitions
      • Engagement in Malign Foreign Talent Recruitment Programs
      • Funding from non-US governments
        • To ensure meeting Ohio Senate Bill 1 (SB1) requirements

What happens after IPTalons review?

  • Vast majority (100s in past 4 years)
    • Notified current research security measures are sufficient
      • If collaboration with researcher associated to Chinese entity
        • Additional information/reminder provided on how to remain compliant with SB1
  • Small number (~<10 in past 4 years)
    • Work with chair/unit head and individual to develop management plan
      • Collaboration allowable within additional research security parameters
  • Infrequently (~5 in past 4 years)
    • Collaboration disallowed 
    • Due to federal prohibition (e.g., membership on Entity List)

J1 Scholar

When inviting scholar to Miami for a lecture, as a volunteer, as a J-1 Scholar, in any capacity:

  • At least 15 days prior:
  • Contact Global Initiatives for any other scenario 
  • Contact grant manager if work/travel is charged to a grant or contract

Material Transfer Agreements (MTAs), Data Use Agreements (DUAs), and Non-disclosure Agreements (NDAs)

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

  • 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

Your contacts at Miami for help

Research Security:
Visiting Scholars and International Travel
Material Transfer Agreements (MTAs), Data Use Agreements (DUAs) and Non-Disclosure Agreements (NDAs):

 

CITI training modules may be of great help to you and your research group

  • Use Miami log-in
Susan McDowell
Export Control

Dr. Susan McDowell

Roudebush Hall, 102
Oxford, OH 45056
513-529-3603