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The first step to ensure ongoing export controls compliance for CU ºù«ÍÞÊÓƵ researchers lies in timely disclosure of any external activity or engagements that overlaps in substance or form with their research portfolio.

The Disclosure of External Professional Activities form (from here, the DEPA) is the initial lens through which OEC will look to inform CU researchers about potential issues in foreign collaborations. In most cases, a potential or actual conflict can be resolved and mitigated with no further implications for export controls. If, however, a researcher has an undisclosed and unmitigated conflict of interest, they may face a cascade of negative implications. For OEC purposes, the most significant implication is that certain university research is no longer fundamental in nature, but is, in whole or in part, proprietary and therefore subject to export controls.