What's New?
The Research Security Centre is pleased to invite you to attend the following presentation by Global Affairs Canada’s Sanctions Bureau:
Canada's use of sanctions has increased in recent years, in particular following Russia's invasion of Ukraine in 2022. To support Canada’s autonomous sanctions, the Sanctions Bureau was created at Global Affairs Canada and funds were earmarked for the Royal Canadian Mounted Police to assist in identifying and investigating sanctions violations. Global Affairs Canada is leading outreach efforts across Canada to ensure Canadians understand how sanctions may apply to their activities or their work. The Global Affairs Canada sanctions team will lead a presentation entitled "Sanctions 101". The presentation will provide an overview of Canada's current sanctions measures, best practices on how to conduct due diligence to verify sanctions, and information on how to apply for a permit, if one is required. Sanctions have implications for Canadian educational institutions, affecting research collaborations and funding opportunities, as well as how researchers and other academic personnel engage with international partners and entities in countries subject to Canada’s sanctions.
Date: Tuesday, November 26, 2024
Time: 1:00pm - 2:15pm EST
Please register here with a university or professional email address and note that we will not be granting access to the AI Notetaker feature. Otherwise, your registration may be denied.
In alignment with new federal and provincial guidelines, the Vice-Principal Research portfolio supports the Queen’s community in safeguarding research.
Mitacs has developed a Research Security Plan, which was drafted based on consultations with Canadian research organizations and academic partners, and further updated based on feedback from Innovation, Science, and Economic Development Canada (ISED).
Visit the Mitacs website for the most recent version of the plan.
What is Research Security?
In Spring 2021, the Government of Canada released a policy statement to enhance research security and encourage all involved in research to take precautions to protect their research. In this context, research security refers to “the ability to identify possible risks to your work through unwanted access, interference, or theft and the measures that minimize these risks and protect the inputs, processes, and products that are part of scientific research and discovery.” ( Safeguarding Research, Government of Canada, 2021).
Institutional Priorities
Taking precautions to mitigate risk is part of best practices to discovery-driven and partner-based research. The Vice-Principal Research portfolio is committed to supporting Queen’s researchers in navigating geopolitical risks in research. Our team will keep track of current policies and guidelines, identify risk assessment tools, and provide training for researchers and research staff.
For more information on Safeguarding Research at Queen’s, read the Institutional Strategy and Guiding Principles.
Support Available for Queen’s Researchers
The Research Security team in the Vice-Principal Research portfolio supports researchers in:
- Risk assessment
- Risk mitigation
- Research involving sensitive technology research areas
- Research involving international partner organizations
- Legal agreements and contracts
To connect with our Research Security team, e-mail us at researchsecurity@queensu.ca.
Research Security & Funding
Research security guidance and requirements vary across funding programs and agencies. Refer to the lists below for current information:
Canadian Programs
This policy, developed by the federal government in collaboration with implicated federal departments and agencies, aims to further protect Canada's research, research institutions, and intellectual property.
View the STRAC Policy
View the STRAC Policy FAQ
View the Named Research Organizations List
View the Sensitive Technology Research Areas List
STRAC Affiliation Self-Assessment Questionnaire - English (51.7 KB)
STRAC Affiliation Self-Assessment Questionnaire - French (51.7 KB)
The federal granting agencies are committed to providing our research community with the most up-to-date information and best practices to safeguard their research and to mitigate research security risks.
In support of this commitment, they have launched a new Tri-Agency Guidance on Research Security webpage.
Included in this webpage is the Tri-Agency Guidance on the Policy on Sensitive Technology Research and Affiliations of Concern (STRAC Policy). Detailed information, including the attestation form, procedures, resources, and frequently asked questions are now available. This webpage also includes Tri-Agency Guidance on the National Security Guidelines for Research Partnerships, as well as a list of recommended research security resources.
These Frequently Asked Questions (FAQ) address potential questions related to the letters that have been appended to notices of decisions (NODs) for research grants from the federal granting agencies, with regards to the statement on protecting Canada’s research issued by the Minister of Innovation, Science and Industry, the Minister of Health, and the Minister of Public Safety, on February 14, 2023.
Institutions applying for or receiving CFI funding have research security obligations both when they apply for funding as well as after they receive funding and throughout the life of the project.
To learn more about CFI's approach to Research Security, visit the website.
Based on consultations with Canadian research organizations and academic partners and feedback from Innovation, Science, and Economic Development Canada (ISED), Mitacs has developed a Research Security Plan.
For more information on Mitacs and Research Security, visit the website.
The National Research Council of Canada (NRC) is Canada's largest federal research and development organization and is committed to advancing research and supporting innovation in the interests of Canada.
Guidelines: Provide Ontario's institutions and researchers with an overview of the research security requirements and processes when they apply for a research funding program under the Ontario Ministry of Colleges and universities.
English version
French version
Application Attestation Form: All named researchers in an application are required to complete and sign the Application Attestation Form when they apply for a research funding program under the Ontario Ministry of Colleges and Universities.
English version
French version
Mitigating Economic and Geopolitical Risk Checklist: The Principal Investigator is required to complete the Mitigating Economic and Geopolitical Risk Checklist for Ontario Research Fund Applications when applying for a research funding program under the Ontario Ministry of Colleges and Universities.
English version
French version
Foreign Talent Recruitment Programs (FTRP): Those applying for or holding United States (US) federal government research funding or Ontario Research Fund funding should be aware of the potential negative effects of participating in FTRPs. In both cases the funders consider participation in such programs giving rise to potential conflicts of interest which may raise research security considerations and could lead to a denial of funding.
International Programs
US Federal Grants: Investigators from Canadian institutions may be eligible to apply for certain research funding programs offered by the Federal Government of the United States. Some funding agencies include the Department of Defense (DOD), National Institutes of Health (NIH), and National Science Foundation (NSF).
Check the eligibility criteria and access information and resources.
Foreign Talent Recruitment Programs (FTRP): Those applying for or holding United States (US) federal government research funding or Ontario Research Fund funding should be aware of the potential negative effects of participating in FTRPs. In both cases the funders consider participation in such programs giving rise to potential conflicts of interest which may raise research security considerations and could lead to a denial of funding.
- Queen's NetID required to view the full document.
Export Controls and Canadian Sanctions
Export controls are applied by many governments, including Canada and the United States of America (US), as a means to regulate, and sometimes deny, trade in specific goods and technologies.
The main aim of export control regulations is to ensure that exports of certain goods and technologies are consistent with Canada's foreign and defence policies, as well as Canada’s obligations under bilateral and multilateral treaties and agreements.
In Canada, permits to export items included on the Export Control List (ECL) or to countries included on the Area Control List are issued by the Minister of Foreign Affairs under authority granted in the Export and Import Permits Act (EIPA).
Queen's researchers should note that the export of all goods and technology of U.S.-origin, defined in Item 5400 on the ECL, regardless of their nature and destination, require permits from the Export Controls Division of Foreign Affairs, Trade, and Development Canada.
Queen’s researchers should also be aware that non-compliance with Canada’s export and brokering controls under the EIPA may attract the following penalties:
- for a summary-conviction offence, a maximum fine is $250,000, imprisonment for up to 12 months, or to both a fine and imprisonment.
- those convicted of an indictable offence remain liable to a fine in an amount that is at the discretion of the court, to imprisonment for a term not exceeding ten years, or to both.
If your research involves items subject to export control, please contact the Research Security team in the VP Research at researchsecurity@queensu.ca.
For more information, access:
Export and Brokering Controls Handbook
A Guide to Canada’s Export Control List
Goods, technologies and data obtained from outside Canada or inside Canada but originating outside Canada may be subject to the export control regimes in the originating country. This is the case for goods and technologies of US origin.
US export controls are divided into 3 systems:
- the International Traffic in Arms Regulations (ITAR) (administered by the State Department) regulates the export of defence items;
- the Export Administration Regulations (EAR) (administered by the Commerce Department) regulates the export and the re-export of commercial, dual-use items; and
- the Office of Foreign Assets Control (OFAC) (administered by the Treasury Department) regulates economic sanctions.
Technology is defined in the EAR to include any information necessary for the development, production, use, operation, installation, maintenance, repair, overhaul, or refurbishing of an item.
One issue of concern for Queen’s researchers using goods or technologies of US origin is the concept of "deemed reexport".
Queen’s researchers should also be aware that the EAR also contain a list of names of certain foreign persons – including businesses, research institutions, government and private organizations, individuals, and other types of legal persons – (the Entity List) that are subject to specific license requirements for the export, reexport and/or transfer of specified items. The Entity List was first published in February 1997 as part of its efforts to inform the public of entities who have engaged in activities that could result in an increased risk of the diversion of exported, reexported and transferred items to weapons of mass destruction (WMD) programs. Since then, the grounds for inclusion on the Entity List have expanded to activities sanctioned by the State Department and activities contrary to U.S. national security and/or foreign policy interests.
If you believe your research may include items subject to the EAR, please contact the Research Security team in the VP Research at researchsecurity@queensu.ca.
For more information, access:
Deemed Reexport Guidance
Items covered by the EAR
Entity List under the EAR
In Canada, the Controlled Goods Program (CGP) is a domestic industrial security program administered by federal government through Public Works and Government Services Canada (PWGSC) under the Controlled Goods Directorate (CGD). The CGD’s objective is to safeguard tactical and strategic assets in Canada and to prevent those controlled goods, including US ITAR controlled articles. from being accessed by unauthorized persons. The official details of controlled goods and/or controlled technologies can be found here.
Organizations and individuals who conducts business in Canada (including research) and examine, possess and/or transfer controlled goods in Canada must comply with the Defence Production Act (DPA). These individuals and organizations need to be registered in the CGP. Queen’s University is currently registered in the CGP and the Environmental Health and Safety department has oversight responsibility for the program.
While the University is registered, the University must update the CGP whenever there are any changes to locations on campus where controlled goods are examined, possessed and conduct security assessments of any individual authorized to examine, possess, or transfer controlled goods at the University among other obligations.
Under the DPA, every registrant who knowingly transfers a controlled good to, or permits the examination of a controlled good by a person who is not registered or exempt from registration, is guilty of either:
- an offence punishable on summary conviction and liable to a fine not exceeding $100,000 or to imprisonment for a term not exceeding two years, or to both.
- an indictable offence and liable to a fine not exceeding $2,000,000 or to imprisonment for a term not exceeding 10 years, or to both.
Any individual wishing to examine, possess or transfer controlled goods at Queen’s must obtain authorization through EH&S. If you believe your research project may include controlled goods, please contact Environmental Health & Safety.
For more information, access:
What are controlled goods?
How to meet the Controlled Goods requirements?
Exemptions from Registration in the Controlled Goods Program
Canada imposes sanctions on various foreign actors under three statutory regimes: United Nations Act (UNA); Special Economic Measures Act (SEMA); and Justice for Victims of Corrupt Foreign Officials Act (JVCFOA). These sanctions are imposed in response to:
- grave breaches of international peace and security that have resulted in or are likely to result in a serious international crisis;
- gross and systematic human rights violations; or
- acts of significant corruption.
The sanctions are imposed either independently by Canada or in order to fulfill its international legal obligations as a United Nations member state.
While Queen’s University and students and employees of the institution need to be concerned about breaching any of the sanctions imposed by Canada, of particular concern are the sanction imposed under SEMA. SEMA sanctions currently apply to several countries, including individuals and institutions from these countries. Several universities are also listed among the sanctioned entities. The sanctions imposed by Canada contain a broad range of prohibitions, including prohibitions of dealings with individuals and entities and restrictions on trade and financial transactions. Some of these prohibitions may capture some of the activities researchers and academics engage in as part of the collaboration activities.
Contravening sanctions is considered a criminal act in Canada. Where individuals and/or entities are convicted of a breach of any sanction imposed by Canada it could result in fines ranging from $25,000 to $100,000 and/or prison terms ranging from 1 year to 10 years depending on the sanctions legislations that is breached. Additional penalties can also be imposed for related breaches of other legislation including the Criminal Code and the Export and Import Permits Act.
It is therefore important for members of the Queen’s community to be aware of the entities and individuals they are dealing with and whether those individuals or entities are sanctioned or otherwise connected with sanctioned actors.
Please review a list of the current sanctions maintained by Canada, including affected individuals and entities.
In addition, any questions or concerns that you may have about whether an interaction could be a breach of any sanctions can be directed to the safeguarding research team at Queen’s by emailing researchsecurity@queensu.ca.
For additional information visit Canadian Sanctions FAQs.