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 ↓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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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.
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.
Seven agents read the agreement, the spec sheets and the team, and sort every item inside or controlled; the officer signs.
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.
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.
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."
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.
"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.
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.
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.
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.
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.
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.
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.
The same defense subcontract, seen by the four people who answer for it: what their week looked like, and what it looks like now.
Seven agents read the agreement, the spec sheets and the team, and sort every item inside or controlled; the officer signs.
Screens every new award and proposal overnight for export signals: sponsor type, keywords, equipment and foreign parties. Prefills the PI's export questions.
Reads the agreement for publication approval, foreign-national restrictions and controlled-information clauses, and proposes replacement wording from the playbook and earlier agreements.
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.
Argues the other side of every classification: the military entry first, then the next-lower entry, then the vendor's own classification.
Runs restricted party screening on visitors, collaborators, sponsors, vendors and shipments, and proposes how to clear a potential match.
Works out what each foreign person would receive: operating an item, its "use" technology or technical data, and proposes access conditions.
Writes the technology control plan, per-person briefings, license application drafts, TMP letters and I-129 Part 6 attestations.
Sign, clear and file. The agents propose; a named person decides.
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.
13 screens from the working solution, on its sample data. Pick one to see it large.
Thresholds, service levels and records are settings, versioned, and every change needs a second administrator.
| Setting | Default | Choose from |
|---|---|---|
| Proposal confidence | 0.90 | Below it, the Equipment agent asks the analyst instead of proposing |
| Ask-the-analyst floor | 0.70 | Below it, no proposal at all |
| Challenger on every classification | Required · locked | A second key before the officer can sign |
| Screening match threshold | 0.80 | Name similarity that opens a potential match |
| New award screening | 5 business days | Deep classification 10 business days; I-129 attestation 5 |
| Visitor screening | 3 days before arrival | Escalation past the service level: Director of Export Controls, then the AVP |
| Retention | 5 years | From the last export activity (15 CFR 762.6, 22 CFR 122.5); legal hold per project |
| Citizenship and visa status | Masked · officer and analyst | Reveal with a reason; auditor packs redact student ID numbers and country |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Five high-fit calls in minutes, each limit and cost share cited to the sponsor's own text.
1-min demoGrant Proposal ReviewEvery proposal reviewed inside the five-day window, every value tied to its clause.
1-min demoSubrecipient Risk Assessment & MonitoringRisk scored before signing and every invoice line checked before the university pays.
1-min demoWe'll run Research Export Control Review on a sample of your own agreements, requisitions and project teams.