Posted on behalf of Glenn Swafford, Head of Research Services
Arising from a recent meeting on Export Controls between Research Services, Legal Services, OUI and departmental colleagues, I wanted to highlight how important it is that researchers including postgraduate research students are aware of their personal legal obligation to comply with the UK’s Export Control Regime. Failure to obtain a licence or to comply with its provisions may constitute a criminal offence involving potential fines, legal costs and/or prison sentences of up to 10 years.
The UK Government aims to control the export of goods, technology, software, designs and related 'know-how' to help protect national and international security. Unilaterally or pursuant to international obligations, the Government also imposes related arms embargoes, trading or other sanctions on certain counties.
Researchers whose work involves actual or potential military uses or who work on materials (physical, chemical or biological) that could be used in weapons or weapons delivery should already be very aware of the ethical and legal issues involved, including export controls. Medical research-related ‘red flags’ include work on viruses and pathogens, and on vaccine technology with military applications.
Perhaps less well known: dual use items (‘technology’) that can be used for civil or military purposes - and which meet certain specified technical standards - may also be subject to controls, high spec imaging equipment e.g. might be on the ‘controlled list’ if it could, in the wrong hands, be used for military or terrorist purposes; the same ‘duality’ applies e.g. to high-tech lasers, advanced processors, etc.
Technology in this context means 'specific information' that is not in the public domain and which is necessary for the necessary for the 'development', 'production' or 'use' of goods or software. 'Export' means the physical removal of goods or the transfer (by any means) of technology or software and/or knowledge from the UK to a destination outside the UK, incl. via email, fax, video-conferences and shared data environments.
Resources on Oxford’s Research Support web site aim to assist our researchers to identify whether their work may be subject to Export Controls - - if it is, then they must make a licence application to the UK’s Export Control Organisation (ECO). The ECO is there to help and advise. See http://www.admin.ox.ac.uk/researchsupport/contracts/export/
Please don’t hesitate to contact Glenn Swafford if you have any questions.