Free Foreign Datasets – Can We Use Them?

I have a PI that is asking if he can use datasets from a UK professor on his SBIR Phase I DoD contract. This professor wants to “give” these datasets to the PI (no formal Agreement, SubK, PO, etc.) – he’s just willing to share his data. My gut says no due to the SBIR guidelines that we can use a foreign Sub, vendor, etc. but the work needs to be done in the US and this work was already done in the UK. But I’m not sure if that holds true if we aren’t actually paying for the datasets?