Division of General Counsel, Governance and Compliance

Managing risks in Internationalisation

Sussex has an international outlook and with its extensive global engagement comes a wide range of risks.

This page provides guidance and associated policies to staff to support them in ensuring that these risks are identified and mitigated.

For more information on international partnerships, please see our International Partnerships and Collaborations webpage.

If you have a query about Export Controls, please contact exportcontrols@sussex.ac.uk. 

Export Controls

What are Export Controls?

UK Export Controls restrict the transfer of sensitive goods, software, information and technology overseas. This includes physical exports, electronic transfers (via email, file sharing, virtual meetings, etc.), and transfers by any other means (verbal communication). They apply to academic research and teaching in the same way as to trade and commerce.

Where do Export Controls come from?

UK Export Controls derive from international obligations, including those under UN Security Council Resolution 1540, the Chemical Weapons Convention, the Wassenaar Arrangement, and other treaties. They help to preserve national and international security by preventing Weapons of Mass Destruction (WMD) proliferation and countering terrorist threats. They also help prevent the violation of fundamental human rights including by torture, repression and capital punishment.

How do Export Controls work?

The UK Strategic Export Control Lists designate goods, software and technology that are controlled for the purposes of export. Other reasons for Control are concerns that the recipient may use the items for military or WMD purposes, or for human rights violations. Where a transfer or export falls under one or more of the Controls, an export licence may be required. Licence applications and enquires are administered by the Export Control Joint Unit (ECJU) within the Department for International Trade (DIT).

The Export Controls Organisation has issued a short introductory film to explain Export Control and why it is important. 

It is important to consider whether you might require an export licence as early as possible when planning any research or teaching activity that involves overseas participants (students, collaborators, funders, etc.). The ECJU aims to turn around most licence applications within 20 working days. However, complex applications involving sensitive materials, regions or entities may take much longer (up to several months).

Who is most likely to be affected?

In the academic context, export controls are most likely to apply in relation to scientific and technical research with potential military or WMD applications, particularly relating to:

  • the development of military and security-related goods, software or technology;
  • nuclear science or engineering;
  • missiles, aerospace and space technology;
  • autonomous vehicles and stealth technology;
  • some high strength materials and material production techniques;
  • some chemicals with toxic properties;
  • some viruses, pathogens and vaccines;
  • some sensors and lasers;
  • some high specification electronics and cryptography.

However all researchers, particularly those in the scientific and engineering disciplines, need to be aware of and comply with export control regulations. This forms part of the duty for all researchers to ensure that any University business they undertake is carried out in compliance with all applicable legal obligations (see the University’s Financial Regulations Section 2).

For support, contact exportcontrols@sussex.ac.uk. 

 Sensitive Technology Transfers and Export Controls Policy (v1.2)

 Further guidance for Export Controls applying to academic research

Sanctions

Why are sanctions important?

The University must comply with UK and international sanctions laws. Non-compliance could lead to fines, withdrawal of funding, and reputational damage. 

You will need to think about sanctions when:

  1. You work with an individual, company, or entity from a sanctioned country or region;
  2. You travel to a sanctioned country or region for University work;
  3. You do something which creates an obligation for the University, such as sign a contract which requires the University to abide by new rules or laws.

Sanctions Policy, Oct 2022 

Further advice: https://www.sussex.ac.uk/finance/how/sanctions  Russia sanctions: guidance - GOV.UK (www.gov.uk)

National Security and Investment Act Jan 2022

The National Security and Investment Act 2021 (the NSI Act) came into force on 4 January 2022. The NSI Act establishes a new, stand-alone statutory regime for government scrutiny of, and intervention in, acquisitions and investments for the purposes of protecting national security.

The new rules cover qualifying acquisitions of certain entities and assets, which are likely to affect some parts of the higher education and research sectors. UoS should have full awareness of the NSI Act and the new legal duty to notify the government when collaborating with other parties to acquire, sell or develop qualifying entities or assets. The government will have powers to block or unwind transactions and impose sanctions for non-compliance.

An online notification process has been established. This flowchart can help organisations decide whether they need to notify the government about an aquisition.

Links to the mandatory, voluntary and retrospective forms can be found here

Guidance for the NSI Act

National Security and Investment Act: guidance for the higher education and research-intensive sectors

UUK NSI Guidance [PDF 433.40KB]