Events

Add this event to your calendar

The purpose of this session is to provide an overview of the context around managing risks in internationalisation, what university work is subject to export controls, sanctions, the National Security and Investment Act (NSIA), and the Foreign Influence Registration Scheme (FIRS), what due diligence processes are necessary, how to manage licensing if it is required and the University's policies on these issues.

The session will take place via Microsoft Teams and will be recorded.

To sign up, please contact Chloe Ratcliffe Schofield (c.ratcliffe-schofield@sussex.ac.uk). 

Legal Background

A government licence is required to export or transfer military or dual-use goods, software and technology out of the UK to prevent sensitive capabilities falling into the wrong hands. Such items originating in the US may require a US licence, even for transfers within the university or the UK. Sanctions restrict interactions with sanctioned persons, organisations and countries, and are of course now particularly prominent elements of Western policy towards Russia. The NSIA regulates investments and transfers of IP to protect national security. FIRS requires organisations that act 'on the direction of a foreign power' to register with the government, to ensure transparency. Violations can result in heavy fines, reputational damage and up to 10 years imprisonment.

Relevance for universities

These laws do not apply to the great majority of university activities. The main risk is if any research activities fall within the definition of dual-use, which can be difficult to determine, or if we are notified that the UK government has concerns that one of our overseas partners may intend to use the results of our research for military or WMD purposes. In this case, a licence would be needed before, for example, sending or carrying unpublished research work overseas or exchanging laboratory equipment or materials with overseas collaborators. Additionally, a growing risk lies in breaching sanctions in relationships with new partners, overseas or even in the UK. Since such cases are rare, universities need a systematic and proportionate approach to internal compliance measures which do not impose an undue burden but provide confidence that any such activities are identified at an early stage and appropriately managed.

Trainer

Richard Tauwhare works in the International Trade team of Fieldfisher, a prominent UK law firm. Richard specialises in US, UK and EU export controls, sanctions and trade compliance. He has 35 years’ experience in the Foreign and Commonwealth Office including heading the department responsible for UK policy on arms and dual-use exports, and trade sanctions. He worked in an international law firm, Dechert, for four years and has worked with Fieldfisher for six years, assisting a wide range of UK, EU and US organisations, including over a dozen UK universities and research bodies.

Back to all events