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Trade controls on software and technology are essential to controls on sensitive goods. But deciding whether the transfer of a particular piece of 'know how' is subject to controls is challenging, particularly when it might be made simply in an email or even, in some cases, face-to-face conversation. These challenges are compounded by decentralized structures, competition for research funds and strong traditions of academic freedom in UK universities. Few of the top twenty-four research universities in the UK have a formal export controls policy in place, underlining the need for renewed efforts1 to develop more, and more practical, guidance for the universities. This article looks at the controls which apply to intangible transfers of technology by UK universities and the challenges in implementing them, and suggests some approaches to achieve compliance in a practical, proportionate way.
Global Trade and Customs Journal