Typically, a TCP is in place to ensure no items or information will be exported to foreign nationals. Thus, there is likely a restriction on the involvement of foreign students (who would likely be considered a foreign national). However, even though there are restrictions on who may participate in the research, you can still apply for an export license to get permission for the foreign national to be involved.

There are several reasons why a TCP may still be required for fundamental research:

• If you are receiving controlled items or information for the research, those items or information are still subject to export controls and therefore require a TCP;
• Contractually, you may be required to have a TCP;
• There may be publishing restrictions. Even though you may be permitted to publish the research, if the agreement gives authority to the sponsor to limit publication, a TCP is still required;
• There are restrictions in the research agreement, either for foreign national participation or regarding proprietary information (e.g. a requirement to sign an NDA);
• The research itself may be fundamental, but it may not be subject to the fundamental research exclusion, for some of the reasons described above.

Typically, yes. UA maintains a secure environment for protecting information, which costs the University funds and personnel time to maintain. Further, each research project that interacts with controlled information must have a secure space setup in the larger environment. The cost of that project-by-project space must be paid by the researcher. The costs of the cyberspace include:

• An annual license fee for each user. The license fee includes standard cloud-based storage and use of Microsoft Office products (e.g. Teams, Word, Excel, etc.);
• Costs for compute resources. If you do not need any special resources, the base cost for this line item is ~$250/month. Costs go up with requests for high RAM compute, GPU compute, or other non-standard needs; and
• Any software licenses (if not already purchased) for deploying the analysis software in the secured environment.

Sponsored Programs, Pre-Award, include a line item in the budget template, to assist in calculating the costs as you apply for grants. IT can assist with a more in depth discussion of the compute time and power costs.

Additional costs may include:

• Costs of additional hardware (e.g. encrypted hard drives for moving data from unique equipment to the controlled environment);
• Costs to secure any tangible items that are export controlled, such as a safe, new locks for the physical space, or other physical security devices; and/or

It is best to determine these costs during the application or contract negotiation phase, so you can ensure you have the funds to pay for them. The PI is typically repsonsible for costs that are directly and specifically needed for the project.

When research involving export controlled information is conducted on shared equipment, additional safeguards must be put in place. These safeguards are made on a project-by-project basis. Some safeguards may be:

• Reserving the shared equipment and working with it when no other personnel are around;
• Removing the export controlled information from the shared equipment computer and putting it on an encrypted external drive; and
• Performing a "secure wipe" of the hard drive sectors where controlled information was used or created, for each session and before the researcher leaves the shared equipment, thereby permitting access by other researchers;

Sponsored Programs, Pre-Award, include a line item in the budget template, to assist in calculating the costs as you apply for grants. IT can assist with a more in depth discussion of the compute time and power costs.