WorkflowResearch Administration & Compliance

Research Export Control Review

Research export control that sorts every clause, item and person inside fundamental research or controlled, cited and signed

Projects classified with cited reasoning before work starts, and a file ready for BIS.

See one case, screen by screen ↓
demo12itemsclauses, equipment, software and people on one defense subcontract, each sorted with a cited reason
demo3itemsmoved back inside fundamental research when the sponsor accepted new wording, and the plan fell from 6 controls to 4
target100%of new awards screened for publication and foreign-national restrictions before work starts
target5daysfrom a new award to a signed export determination
In short

What is Research Export Control Review?

Research Export Control Review is research export control software for university export officers. Agents read each new award's agreement for publication and foreign-national restrictions, classify purchased equipment under EAR and ITAR, screen visitors and work out deemed exports, then sort every clause, item and person inside fundamental research or controlled, with a cited reason. The export control officer signs every classification and technology control plan.

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Updated

The problem

Why research export control is decided late, one clause at a time

Research export control at a university turns on the fundamental research exclusion: results the university is free to publish are not subject to the EAR (15 CFR 734.8) and are in the public domain under ITAR (22 CFR 120.34(a)(8)), so almost all of its research sits outside export controls. The exclusion is lost one clause at a time. A sponsor that must approve publications, an item of controlled equipment in the lab or a sponsor's controlled data turns open work into controlled work, and then a foreign graduate student in the room is a deemed export to their home country (15 CFR 734.13(b)).

Today a university export control office finds those clauses, items and people by hand: reading defense and industry agreements page by page, classifying a camera from a vendor email, pasting visitors into a screening box and clearing potential matches in email with no reason recorded. The reasoning ends up in five systems when the regulator asks. Research Export Control Review puts agents in front of that reading, and the export control officer decides and signs.

typical$374,474per violationmaximum civil penalty under the Export Control Reform Act, from January 15, 2025
typical42alleged violationssettled by one public university with the Bureau of Industry and Security in 2024
typical$54,000and two auditspaid and agreed by another university in a 2021 export settlement
Where a defense award's export review days go, in business daysestimated
By hand13 days
With the solution2.3 days
  • Reading the agreement for publication and foreign-national restrictions3 → 0.5 d
  • Classifying each purchased item against the USML and the CCL3 → 0.5 d
  • Working out what each foreign person on the team would receive2 → 0.3 d
  • Screening visitors and collaborators and clearing potential matches1 → 0.3 d
  • Writing the technology control plan and the team's briefings3 → 0.5 d
  • Signatures, acknowledgments and filing the record1 → 0.3 d

Estimated split of the office's working time on one defense award with controlled equipment and foreign team members, by hand and with the agents; the sponsor's own time to answer a clause negotiation is outside it. Our arithmetic, kept modest.

How it works

How a new award moves

Seven agents read the agreement, the spec sheets and the team, and sort every item inside or controlled; the officer signs.

What comes in
Records in5 systems an award · agreement, requisition, spec sheets, team, visitors
Agents at work
Intake agentevery award, overnight
Then
Clause agentpublication, people
Equipment agentspec vs control text
Then
Challenger agentargues the other side
Screener and Accesswho receives what
Then
Draftercontrol plan, briefings
A person decides
Export control officersigns every classification and plan
What comes out
Exclusion decided
Control plan signed
Inquiry pack ready
One case, step by step

One defense subcontract, through research export control review to a signed plan

Project AWD-26-1147, "Vision-based navigation for small uncrewed aircraft without GPS": a $1,184,000, 24-month subcontract from Corvane Aerospace Systems under a Department of Defense prime contract, starting Monday, November 2. Here is Wednesday, October 21, screen by screen, in the working solution.

  1. 01Overnight

    Every new award read before the office opens

    Intake agent

    At 11:52 p.m. the Intake agent read 14 new awards: sponsor, terms, keywords, purchases and people. Thirteen are inside fundamental research, each with its reason, for a spot check. One goes to deep review: a defense subcontract with a publication clause and a controlled camera.

    One export violation can cost up to $374,474.

  2. 0211:53 p.m.

    The clause that loses the exclusion, found in 31 pages

    Clause agent

    The Clause agent found three clauses. Clause 14.3 makes every release wait for Corvane's written approval, a flow-down of DFARS 252.204-7000, so the exclusion is lost. Clause 9.4 is a notice only, and clause 22.1 is not triggered because the statement of work says no covered defense information will be furnished.

    "No information resulting from the Work shall be released, published or presented by Subcontractor without the prior written approval of Corvane."

  3. 039:14 a.m.

    The exclusion board: inside fundamental research, or controlled

    Lenora Vasquez-Hart · Export Control Officer

    One vertical line splits the board. Six items sit inside, including the ODI-9 IMU (7A994), the flight controller and six routine lines (EAR99) and the visiting researcher, screened clear. Six are controlled: clause 14.3, the Lumivane TX-640 thermal camera, its service manual, the navigation code, the flight-test data and papers, and the two foreign graduate researchers' lab access. Each shows a one-line reason, a numbered citation and who stands behind it.

  4. 04One click

    The agents show their plan, sources, confidence and hand-off

    The agents

    "Run the agents again" replays the work step by step: the Clause agent at 0.97 on clause 14.3, the Equipment agent at 0.94 on the camera, USML first, the Challenger's check, the Screener and the Access agent on five people and one visitor, then the Drafter. Each item moves to its side as its step finishes, and the work is handed to Lenora.

  5. 05Two keys

    A thermal camera classified from its spec sheet, and argued the other way

    Equipment agent and Challenger agent

    The TX-640 is matched to ECCN 6A003.b.4.b parameter by parameter: not specially designed for a military end item, an uncooled 640 × 512 microbolometer at 12 µm, and a 60 Hz frame rate, above the 9 Hz line that would make it 6A993.a. The Challenger argued USML Category XII and 6A993.a and agrees. The vendor's quote says the same. Lenora signs at 3:10 p.m.

    A disagreement between the two agents is escalated to the officer, never averaged.

  6. 06Deemed export

    What each foreign student would actually receive

    Access agent

    Tomas Reyes Aldana and Nadia Haddad, graduate researchers on F-1 status, may operate the camera and work on the results. Operating is not "use" technology, which needs all six of operation, installation, maintenance, repair, overhaul and refurbishing (15 CFR 772.1); the service manual would need a license, so it stays locked. Their citizenship stays masked behind a logged Reveal.

    Confidence 0.92: access under the plan, no license needed, manual locked.

  7. 079:40 a.m.

    Replacement wording with precedent, sent by Sponsored Programs

    Lenora, then Owen Pradhan · Contracts Officer

    Lenora proposes the playbook's wording P-2: a 30-day review for comment, with the decision to publish left to the university, accepted by Corvane in two earlier subcontracts. She cannot send it herself. Owen Pradhan sends it to Corvane from the research administration system at 10:02 a.m.

  8. 082:20 p.m.

    The clause comes out, and the research is open

    Corvane accepts Amendment 1

    Lenora records the sponsor's reply and applies it to the board. Clause 14.3, the navigation code and the flight-test data move back across the line: nine items inside, three controlled. The drafted plan drops from six controls to four.

  9. 095:05 p.m.

    A technology control plan written from the controlled side

    Drafter, then Lenora

    TCP-26-061 for Room 2.114 has four controls, each tied to the item that needs it: physical security, information security, personnel, and travel and shipment. Dr. Thornbury and both students acknowledged their plain-words briefings at 4:40 p.m. Lenora signs at 5:05 p.m. No license is needed, so nothing goes to the empowered official.

  10. 10On the record

    Every step in one inquiry pack

    Janelle Okoro · Internal Audit

    The audit trail runs from the Intake agent's flag at 11:52 p.m. to the plan signed at 5:05 p.m.: who, what, when, why and which evidence, for people and agents. Export inquiry pack builds a redacted binder for a regulator, the sponsor or internal audit, kept five years.

Who it’s for

Built for everyone who carries an export review.

The same defense subcontract, seen by the four people who answer for it: what their week looked like, and what it looks like now.

LV
Lenora Vasquez-HartExport Control Officer · classifies items and signs control plans
Export Control Officer
Before
Reads every defense and industry agreement by hand, hunting for the one publication clause before the PI orders anything.
Now
Opens a board where the clause, the camera and the people are already sorted and cited, and spends her day deciding and signing.
MD
Marcus DelacroixExport Control Analyst · screens visitors and shipments
Export Control Analyst
Before
Clears potential matches that are only a shared word in a company name, in email, with no reason kept.
Now
Sees the visitor and the listed party side by side, proposes a clearance with a reason code, and the officer confirms it.
DW
Dr. Douglas WexleyAssociate Vice President for Research Compliance · Empowered Official
Empowered Official
Before
Signs license applications with his name on every line, and checks each one against notes from several people.
Now
Receives a drafted, checked license application that only he can file, with every line cited.
ET
Dr. Elias ThornburyPrincipal Investigator · Aerospace Engineering
Principal Investigator
Before
Waits to hear whether his two foreign graduate students can stay on a defense-sponsored project.
Now
Gets the export questions prefilled and a one-page briefing that says in plain words what his students can and cannot touch.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents read the agreement, the spec sheets and the team, and sort every item inside or controlled; the officer signs.

Intake agent

Screens every new award and proposal overnight for export signals: sponsor type, keywords, equipment and foreign parties. Prefills the PI's export questions.

  • Never clears a defense or foreign-sponsored award on its own
Clause agent

Reads the agreement for publication approval, foreign-national restrictions and controlled-information clauses, and proposes replacement wording from the playbook and earlier agreements.

  • Never sends wording to a sponsor
  • Never decides the exclusion
Equipment agent

Proposes a USML category or ECCN for each purchased item from the vendor's spec sheet and the control text, parameter by parameter, USML first.

  • Never signs a classification
  • Below 0.70 confidence it asks the analyst instead of proposing
Challenger agent

Argues the other side of every classification: the military entry first, then the next-lower entry, then the vendor's own classification.

  • Never averages a disagreement: it escalates to the officer
Screener

Runs restricted party screening on visitors, collaborators, sponsors, vendors and shipments, and proposes how to clear a potential match.

  • Never clears a potential match
  • Never uses a person's ethnicity or name origin
Access agent

Works out what each foreign person would receive: operating an item, its "use" technology or technical data, and proposes access conditions.

  • Never shows citizenship to anyone without need to know
  • Never bars a person from open research
Drafter

Writes the technology control plan, per-person briefings, license application drafts, TMP letters and I-129 Part 6 attestations.

  • Never files a license
  • Never signs
Officer, analyst, empowered official

Sign, clear and file. The agents propose; a named person decides.

Ask in plain words

Ask about any clause, item or person

Open any item on the board and ask. Every answer points to the clause, the spec sheet or the regulation.

Why does one clause lose the exclusion?

Research stops being fundamental when the university accepts restrictions on publication, and ITAR says the same. Clause 14.3 makes every release wait for Corvane's written approval.

Has Corvane accepted other wording before?

Yes, twice: the playbook's 30-day review for comment, in March 2024 and January 2025.

Why not 6A993?

6A993.a covers thermal cameras at 9 Hz or less. Page 2 of the spec sheet says 60 Hz, and the 9 Hz model is a different part number.

Is a license needed for the two students?

Not for operating the camera. Releasing the manual would be a deemed export needing a license for both countries, so the plan keeps it locked.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The exclusion board: inside fundamental research, or controlledProject AWD-26-1147, Dr. Elias Thornbury's drone navigation subcontract from Corvane Aerospace Systems ($1,184,000), starts November 2, in 12 days. Inside fundamental research (6): clause 9.4, a notice to comply with export law; clause 22.1, not triggered; the ODI-9 IMU (7A994); the flight controller and six routine lines (EAR99); two US persons; and a visitor screened clear. Controlled (6): clause 14.3, publication approval; the TX-640 thermal camera (6A003.b.4.b, 60 Hz); its service manual; the navigation code; the flight-test data and papers; and two foreign graduate researchers who need Room 2.114. The technology control plan is drafted underneath.
The export control officer's day, ordered by clockLenora Vasquez-Hart's Today screen: 812 new awards screened this year, 14 of them overnight; 41 open reviews, 17 needing her; 1,214 visitors screened, 14 arriving tomorrow with 1 potential match; 60 active control plans. Overnight the Intake agent cleared 13 awards as fundamental research, each with a reason, and sent 1 to deep review.
The publication clause behind the reasonClause 14.3 of subcontract HSU-CAS-26-02, page 12: no information resulting from the work may be released without Corvane's prior written approval, requested 45 days ahead, a flow-down of DFARS 252.204-7000. Every reason on the board opens its source passage, highlighted.
The agents at work, step by stepOne award, a 31-page agreement, 9 requisition lines, 5 people and 1 visitor. The Clause agent finds 3 clauses (0.97 on 14.3); the Equipment agent proposes 6A003.b.4.b (0.94), USML first; the Challenger argues USML XII(c) and 6A993.a and agrees; the Screener and Access agent clear the people; the Drafter writes the plan and hands it to the officer.
Export control classification with two keysLumivane TX-640 thermal camera, requisition PR-26-08813 line 1, $14,850, proposed as ECCN 6A003.b.4.b. Parameter by parameter against the control text, the deciding one is a 60 Hz frame rate, above the 9 Hz line for 6A993.a. Key 1, the Challenger agent, agrees; key 2 waits for the export control officer, with Sign classification and Override with a reason.
Deemed export review: what each person would actually receiveTwo graduate researchers on F-1 status may operate the camera and work on the results, but not read the service manual. Operating is not "use" technology, which needs all six of operation, installation, maintenance, repair, overhaul and refurbishing, so no deemed export license is needed. Citizenship stays masked behind Reveal, open only to export officers.
Replacement wording, sent by Sponsored ProgramsThe officer proposed the playbook's wording P-2 at 9:40 a.m.: a 30-day review for comment, the decision to publish left to the university, accepted by this sponsor in two earlier subcontracts. Owen Pradhan, Contracts Officer, sends it from the research administration system.
The clause comes out, and the fundamental research exclusion is backAfter Corvane accepted Amendment 1 at 2:20 p.m., clause 14.3, the navigation code and the flight-test data moved back across the line. Inside: 9. Controlled: 3, the TX-640 camera, its service manual and the two foreign graduate researchers' access. The plan drops to 4 controls.
The technology control plan, signed at 5:05 p.m.TCP-26-061 for Room 2.114: controlled, the TX-640 (6A003.b.4.b) and its service manual; not controlled, the results, code and data after Amendment 1; no license needed. Four controls, each tied to the item that needs it. Briefings acknowledged at 4:40 p.m.; next review October 2027.
Restricted party screening: a potential match, cleared by two peopleA visitor's employer, Meridale Photonics Institute, resembles the listed Meridale Photonic Systems Co. (0.81 name similarity). Side by side: a public research institute against a company, different addresses, no shared aliases or web domain. The Screener proposes "not a match" (0.88) without weighing the visitor's name or nationality; the analyst proposes clearance with reason R2 and the officer confirms.
Licenses filed only by the empowered officialLicense application LA-26-007, drafted by the Drafter: two TX-640 cameras ($29,700) to a partner university abroad for ice-surface temperature mapping; the Country Chart says a license is required; the end user screened clear. The officer checked and sent it at 11:05 a.m.; filing is locked to Dr. Douglas Wexley, the empowered official. TMP letters and I-129 Part 6 attestations sit in the same place.
Every step on the record, and one inquiry packWho, what, when, why and which evidence, for people and agents, from the Intake agent's flag on Tuesday at 11:52 p.m. to the plan signed on Wednesday at 5:05 p.m., including the wording sent, the sponsor's acceptance, both keys on the camera and the access approval. Kept five years; the inquiry pack is redacted for a regulator, the sponsor or internal audit.
Export control compliance results for the Vice President for ResearchThis fiscal year: 812 of 812 new awards screened before work started; 4.2 days median from award to signed determination; 0 foreign persons with controlled access before a signed plan; 23 of 27 restrictive clauses negotiated out; 61 deep classifications signed with both keys, 5 escalated by the Challenger, 4 officer overrides with reason codes; 3 licenses filed by the empowered official.
Governance

Built for EAR and ITAR: cited, signed by two keys, on the record.

Two keys on every classificationThe Challenger agent must argue the military entry and the next-lower entry before the export control officer can sign. A disagreement is escalated, never averaged, and an override needs a reason code.
Eight roles, separated by dutyThe officer classifies and signs plans; the analyst proposes screening clearances and the officer confirms them; the contracts officer alone sends wording to a sponsor; the auditor reads and changes nothing. Conflicts are blocked, not warned.
Only the empowered official files a licenseThe Drafter writes the application and the officer checks it, but filing is locked to the empowered official. Nothing is sent to a government portal by an agent.
Citizenship on a need-to-know basisEnrollment and visa status come from the student information system as status only. Citizenship is masked to the officer and analyst, each reveal needs a reason and is logged, and auditor packs never show the country. FERPA applies to graduate researchers' records.
Every reason cites its sourceEach item on the board opens the passage behind it, highlighted: the agreement clause, the spec sheet page, the control list text, the screening record or the regulation.
A complete trail and an inquiry packWho, what, when, why and which evidence, for people and agents, kept five years after the last export activity (15 CFR 762.6, 22 CFR 122.5), with export packs for a regulator, the sponsor and internal audit. Rule changes need a second administrator.
Configuration

Your export control rules, not ours

Thresholds, service levels and records are settings, versioned, and every change needs a second administrator.

SettingDefaultChoose from
Proposal confidence0.90Below it, the Equipment agent asks the analyst instead of proposing
Ask-the-analyst floor0.70Below it, no proposal at all
Challenger on every classificationRequired · lockedA second key before the officer can sign
Screening match threshold0.80Name similarity that opens a potential match
New award screening5 business daysDeep classification 10 business days; I-129 attestation 5
Visitor screening3 days before arrivalEscalation past the service level: Director of Export Controls, then the AVP
Retention5 yearsFrom the last export activity (15 CFR 762.6, 22 CFR 122.5); legal hold per project
Citizenship and visa statusMasked · officer and analystReveal with a reason; auditor packs redact student ID numbers and country
Connections

Works with the systems a research office already runs on

Research administration systemawards, proposals, agreements and the export questionnaire
Procurement and purchasing systemrequisitions, quotes and vendor spec sheets
Visitor managementvisiting scholars, visits and lab tours
Restricted party screening serviceconsolidated screening lists, rescreened on every update
Student information and HR systemsenrollment and visa status only; appointments and I-129 petitions
Learning management systemexport control training for the research security program
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of new awards screened for publication and foreign-national restrictions before work starts
Every new award
before work starts
target
0
foreign persons given access to a controlled item before a signed plan
target
5days
from new award to signed determination

Sources: 15 CFR 734.8 (fundamental research), 734.13 (deemed export), 772.1 ("use"), 762.6 (records) · 22 CFR 120.34 (public domain), 120.67 (empowered official), 122.5 (records) · DFARS 252.204-7000 · Department of Commerce civil monetary penalty adjustment, effective January 15, 2025 ($374,474 per violation) · Bureau of Industry and Security press release on a 2024 university settlement (42 alleged violations) · published account of a 2021 university export settlement ($54,000 and two audits) · "demo" = seen in the working solution, on its sample data · "target" = design goal, measured in the live solution · "typical" = published figures · "estimated" = our arithmetic. Halden State University, Corvane Aerospace Systems, the products and the people named on this page are fictional: characters and sample data in the working solution.

Questions

What university export control offices ask us.

What is Research Export Control Review?

Research Export Control Review is research export control software for university export officers. Agents read each new award's agreement for publication and foreign-national restrictions, classify purchased equipment under EAR and ITAR, screen visitors and work out deemed exports, then sort every clause, item and person inside fundamental research or controlled, with a cited reason. The export control officer signs every classification and technology control plan.

What is a deemed export, and does it apply to graduate students?

A deemed export is the release of controlled technology to a foreign person inside the United States, treated as an export to their home country (15 CFR 734.13(b)). It applies to foreign graduate students only when the work is controlled. The Access agent separates operating an item from receiving its "use" technology, so students stay on the project under a precise control instead of a blanket ban.

What is the fundamental research exclusion?

Information from university research that the institution is free to publish is not subject to the EAR (15 CFR 734.8) and is in the public domain under ITAR. A single clause requiring sponsor approval to publish takes the project out of the exclusion. The Clause agent finds those clauses, and when one is negotiated out, the items it controlled move back inside on the board.

What is a technology control plan?

A technology control plan sets out how controlled items and information on a project are protected: physical security, information security, personnel and travel. Here the Drafter writes it from the controlled side of the board, ties each control to the item that needs it, and writes each person a plain-words briefing to acknowledge. The plan cannot be signed while an item is unsettled.

How does it classify equipment under the USML and the CCL?

The Equipment agent checks the USML first, then matches the vendor's spec sheet to the Commerce Control List text parameter by parameter and proposes an ECCN with its confidence. The Challenger agent then argues the military entry and the next-lower entry. The officer signs only when both keys are present, or overrides with a reason code.

Do people stay in control of export decisions?

Yes. Agents propose and cite; the officer signs every classification and plan, the analyst and officer clear screening matches together, the contracts officer sends every negotiation to a sponsor, and only the empowered official files a license. Agents never clear a potential match, use name origin or ethnicity, or file anything with a government portal.

Can we answer a regulator's inquiry from it?

Yes. Every action, by a person or an agent, is on the audit trail with who, what, when, why and which evidence. The inquiry pack gathers the determination, the clauses, the classification, the screening, the plan, the briefings and the training into one redacted export, kept five years.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents: your export control policy, clause playbook, plan template and a sample of past agreements and classifications. It goes live once every quality gate has passed. We will walk you through it on your own awards first.

See it on
your awards.

We'll run Research Export Control Review on a sample of your own agreements, requisitions and project teams.