Fortifying export control compliance at Lehigh University

Extensive planning leads to readily achievable improvements

• Lehigh University enhanced its institutionwide export control program to boost research security and compliance in the face of an evolving security landscape.
• The university collaborated with stakeholders, conducted internal assessments, and established working groups to develop guiding principles and streamline processes.
• Results included improved compliance processes and a successful audit highlighting Lehigh's proactive stance in export control management.

Export control is not new. However, it has become more urgent for academic research institutions due to stricter federal enforcement, increased threats to research security, and the heightened potential of intellectual property theft.

Export control regulations limit the transfer of items by disclosure to foreign nationals in the U.S. or by taking items outside the U.S. They cover everything from research data to laboratory animals to equipment and supplies and are designed to protect national security, foreign relations, and economic interests.

Lehigh University, a leading private research institution, has received a significant increase in federal research funds in recent years. In response, the university recognized the need for a robust framework to uphold its commitment to meeting regulatory requirements, enhancing operational efficiency, and supporting strategic and principled international collaborations.

Lehigh began by conducting an internal assessment to examine the current state of its export control program and define key performance indicators for success. Two initial components were critical to this phase of work:

During these sessions, it became clear that employees were looking for changes that could be seamlessly implemented in their current job scope. The university minimized disruption and promoted process adherence by embedding changes into daily operations, limiting the need for extensive change management.

The assessment and implementation led to multiple wins, including an enhanced process for identifying export control risks in research awards and contracts. The improvements simplified the task of determining the need for a technology control plan and made implementing these plans more efficient.

Lehigh also successfully implemented third-party software to expedite the restricted-party screening process by reducing manual work and preventing errors.

These transformative efforts helped the university achieve its goal of strengthening its export control framework. Verified by an external audit firm for compliance with federal regulations, the program’s success underscores the university's foresight and leadership.