Red Flag Items for Brown University Researchers

Below is a brief list of conditions that Brown researchers should consider when engaging in activities that involve foreign travel or foreign collaborations. The list is not exhaustive but illustrates common occurrences in which export control restrictions may apply.

 

  • Devices (laptop, cell phone, GPS, etc.) or technology may be shipped or carried for personal use into a foreign country
  • Research Project is not Fundamental Research
  • Research Project will require receiving or using export controlled equipment or technology in the course of the Research Project
  • Industrial proprietary or confidential information may be shipped or carried (e.g., on a personal laptop or cell phone file) to a foreign country.

 

Brown researchers should exercise caution and diligently review the facts of their research activities to ensure compliance with US Export Control Regulations and Brown University Policy.

 

In addition to the items noted above regarding University activities, the Federal Government maintains a list of Red Flag indicators that may be helpful in determining appropriateness of transactions conducted with the outside world. These additional Red Flag indicators for items to watch for with daily transactions are as follows:

 

  • The customer or its address is similar to one of the parties found on the Commerce
  • Department’s (BIS) list of denied persons.
  • The customer or purchasing agent is reluctant to offer information about the end-use of the item.
  • The product's capabilities do not fit the buyer's line of business, such as an order for sophisticated computers for a small bakery.
  • The item ordered is incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry.
  • The customer is willing to pay cash for a very expensive item when the terms of sale would normally call for financing.
  • The customer has little or no business background.
  • The customer is unfamiliar with the product's performance characteristics but still wants the product.
  • Routine installation, training, or maintenance services are declined by the customer.
  • Delivery dates are vague, or deliveries are planned for out of the way destinations.
  • A freight forwarding firm is listed as the product's final destination.
  • The shipping route is abnormal for the product and destination.
  • Packaging is inconsistent with the stated method of shipment or destination.
  • When questioned, the buyer is evasive and especially unclear about whether the purchased product is for domestic use, for export, or for reexport.
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