Frequently Asked Questions

A: Maybe. Export controls and sanctions are foreign policy driven. You cannot attend a conference in a comprehensively sanctioned country/region without an Office of Foreign Assets Control (OFAC) export license in place.

Please note that it is unlikely that such a license will be granted for Iran, Syria, Crimea or North Korea. However, there is still a General License in place for Cuba. Other OFAC sanctioned countries that are not comprehensively sanctioned are reviewed on case-by-case basis.

Please email export@gatech.edu for more details.

A: Yes.

• Report by entering information in the ServiceNow Disclosure System (https://gatech.service-now.com/home/).
• Submit an International Travel Spend Authorization (Go to: techworks.gatech.edu, click on “Workday Financials”. Once in Workday, type “Create Spend Authorization” in the search field.)
• If you have federally funded research, notify your Office of Sponsored Research (OSP) Contracting Officer.

Note: Pay attention to virtual conferences, which may be hosted by other entities.

A: Generally, Georgia Tech recommends faculty refrain from downloading unknown or “throw-away apps” such as the ones used for conferences, to avoid potential data harvesting by the app. Consider the following factors:

• Who developed the app
• Which country is hosting the app
• What data you (the faculty member) have on your cell phone
• If the phone is a GT phone or a personal device
• If you are working on projects involving Technology Control Plans (TCP)-export restrictions and CUI data

If you are unsure or have questions, email ask@security.gatech.edu.

A: You should carefully consider use of public Wi-Fi networks. Read more about securing your wireless devices in public settings here.

A: An international assignment is any instance in which an individual will be working outside the U.S. or collaborating with Georgia Tech from outside the U.S. Even if you are taking a leave of absence to engage in an opportunity outside the U.S., but will maintain a connection with Georgia Tech, it is considered an international assignment.

If you or your Georgia Tech employee (postdoc, staff, GRA) or even a non-Georgia Tech employee “affiliate” (collaborator) need to work outside the U.S (including for a family emergency), make sure to (1) inform your department chair and/or supervisor, and (2) work with your departmental HR representative to submit the International Assignment

Assessment or contact Global HR by submitting a request through ServiceNow. (Go to https://gatech.service-now.com/hr; select “Human Resources”, and then “Online Request” (red box). In the “Short Description” field, type “International Assignment Assessment”. When describing the issue or question, make sure to include the individual’s GTID).

Visit the Global HR Temporary International Assignments page.

A:

A: Foreign influence in an academic setting involves “knowing your customer,” so before engaging in a relationship with a foreign entity, consider the following:

• Who are your collaborators and their institution(s)?
• Who are your international vendors? And visiting scholars?
• What is the ultimate end use of the research?
• Who is ultimately to gain?
• Is this research that will be ordinarily published (fundamental research)?
• Are you (the GT Faculty/researcher) being paid by an outside entity?
• Is the entity(ies)/individual(s) on Restricted Party Screening (RPS) (denied lists)

Foreign influence, particularly concerns related to export & trade compliance, involve U.S. foreign policy and national security concerns.

Foreign influence applies outside of sponsored research. It can involve hosting and hiring individuals, collaborations, international shipping/imports etc.

Federal Government & funding issues:

• These issues have received much attention in relation to National Institutes of Health (NIH) funding but they are relevant to all federal sponsors including Department of Defense (DOD), National Science Foundation (NSF) and Department of Energy (DOE).
• The federal government is currently working on further guidance to all federal funding agencies.
• Until then, the best way for research institutions to stay compliant is to “know your customer”, follow Institute and agency disclosure requirements, and when in doubt, disclose to your federal sponsor through your OSP Contracting Officer.
• An important way NIH, NSF and other federal agencies are attempting to identify issues is through required disclosures, such as “Current and Pending Support and Other Support.” Their stated goals are to avoid Conflict of Interest and Conflict of Commitment and to ensure Transparency. At the same time, they are using this information to ensure they are not surprised to find out after the fact that one of their funded researchers was doing something with a questionable entity (for example on the excluded entities list).

Note: The best way for research institutions to stay compliant is to follow Institute and agency disclosure requirements, and when in doubt, disclose to your federal sponsors through your Office of Sponsored Research (OSP) Contracting Officer.

A: First, it is important to identify the type of collaboration:

• Is the collaboration with an individual or an entity?
• Is it an industry or academic collaboration?

If it is federally-funded research, report the collaboration to your Office of Sponsored Research (OSP) Contracting Officer, even if it is a summer collaboration for a 9-month academic year faculty member.

Note: International collaborations can also include staff, postdocs, GRAs, employees, and affiliates working outside the United States on international assignment.

A: Disclose the investment and your role in the start-up in the ServiceNow Disclosure System on the Office of General Counsel web page.

The COI review compares your sponsored research project topics with the subject matter of the international start-up, to see if they are related. For example, if your research is in Artificial Intelligence (AI) and the start-up works in AI, there might be a conflict of interest. The review will also look at whether your financial interest in the start-up might influence your research objectivity. Restricted Party Screening will be done to make sure the start-up is not on the Denied Entity List or another restricted list.

A: It depends on the sponsor’s requirements and the nature of the consulting. Please contact your Office of Sponsored Research (OSP) Contracting Officer for more information.

For example: NIH current FAQ’s state: “Consulting activities that involve research and fall outside of an individual’s appointment, separate from institution’s agreement, must be disclosed as Other Support.”

A:

A: Conflict of Interest:

• It reasonably appears that a significant financial interest could affect the design, conduct, or reporting of activities funded or proposed for funding by a sponsor; or
• The personal interest of an Employee or his or her Family may prevent or appear to prevent the Employee from making an unbiased decision with respect to the Employee’s employment with the Institute.
• For example: I have an investment in a company that does AI research and my research is also in AI.

Conflict of Commitment:

• It occurs when an employee undertakes external commitments which burden or interfere with the employee’s primary obligations to the Institute.
• Conflicts of Commitment may arise out of consulting arrangements or with an entrepreneurial interest when a faculty member is involved in a startup company.
• Whose interests are protected when a researcher works at GT 40 hours a week but is also supposed to consult for a company 30 hours a week?
• In this case, the employee’s commitment of time and effort are inconsistent with the employee’s commitment to the institution and its interests. Conflict of Commitment may also be related to scientific and/or funding overlap.

A: Yes.

1) Contact your Office of Sponsored Research (OSP) Contracting Officer if you have federally funded research. The Contracting Officer will let you know if you need to report the international affiliation to your federal sponsor.

2) Disclose via the ServiceNow Disclosure System on the Office of General Counsel web page. The COI team will review for any disclosure requirements and ensure there is no Conflict of Commitment.

3) Review Policy 5.6.5 Consulting in the GT Faculty Handbook.

A: Yes.

Both a co-author outside of Georgia Tech and support from another entity are indications that there may be research support or financial interests that should be disclosed.

Note: Federal investigations into lack of disclosure have included reviewing publications for “[f]unding sources that were not disclosed to the funding agency; undisclosed affiliations with institutions other than the awardee; and co-authors affiliated with/funded by non-U.S. institutions.” (Council on Governmental Relations, Federal Focus on Inappropriate Foreign Influence on Research: Practical Considerations in Developing an Institutional Response, August 18, 2021).

A: Yes, you must disclose it via the ServiceNow Disclosure System on the Office of General Counsel web page. Also, if the activities relate to your research and you have federal funding, you must discuss them with your Contracting Officer.

A: Export controls and trade regulations are foreign policy driven. Examples of areas with export control regulations: National Security, Crime Control, Missile Technology, Chemical and Biological Weapons, and items on the U.S. Munitions List.

Export controls restrict the transfer (including showing someone or giving someone) of U.S. information, technology, and software to a foreign person both in the U.S. (this is called a “deemed export”) and in a foreign country, that is NOT in the public domain and will NOT be ordinarily published as part of fundamental research (due to restrictions on publication or access restrictions to foreign persons).

Information, technology, and software are excluded from U.S. export control regulations if it is:

• In the public domain,
• Developed under fundamental research (no restrictions on dissemination-publication or foreign national restrictions), and/or
• Educational course materials published in course catalogues.

All physical exports require an export review. Please contact export@gatech.edu.