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July 2024 Newsletter

Stony Brook University's Research Security Program

Stony Brook University (SBU) is commited to international engagement and global activities, recognizing the importance of these relationships. Our faculty, staff and students are encouraged to participate in these engagements and activities as they may promote the creation of knowledge and enrich learning experiences. In addition, such engagements and activities should be reviewed and conducted in a manner consistent with applicable requirements, including those of federal and state agencies, as well as Stony Brook’s own policies. 

The Research Security Program is here to help foster and support these relationships. As part of our commitment, our newsletters highlight different areas of the program with targeted discussions and case studies.  View Research Security Program newsletters here. 

Questions - Contact the Reseach Security Program 

International Visitors

The SBU community regularly engages with international visitors for university-related business.  People from around the world come to SBU for a variety of reasons (e.g., to study, conduct research, provide services, attend conferences, workshops, athletic or arts events, open-houses, hospital or campus volunteers, graduation, or visit a family member). 

This newlsetter will discuss what to consider when you receive a request from an international visitor, campus policies about visitors, and who can help you with the review and/or answer questions.

International Visitor Considerations 

Who is responsible for reviewing international visitors?

The host (faculty/adminstrative office) is responsible for following campus policies and procedures (discussed below) when hosting international visitors.

The host of the international visitor should conduct an initial review of a potential international visitor and intended activities prior to sending an invitation, collaborating with them, or having them visit the campus. 

Click here to submit a request for an international visitor review to the Research Security Program

Note, generally speaking there is no review required for an international guest/visitor at the University solely for: (1) Sporting event (2) Cultural event at the Staller Center and Wang Center (3) Campus tour or open house event through the Admissions Office (4) Family member of a full time University student visit where access is limited to public areas (5) Medical treatment where access is limited to public areas. 

Why conduct a review of international visitors?

International visitors should be reviewed to ensure compliance with U.S. federal laws and regulations and campus policies. Violations of U.S. federal laws and regulations can be costly to individuals and/or the university.  

Is there a university policy for international visitors?

Yes, the University’s Guest/Visitor Policy expresses its commitment to host international visitors/guests while ensuring compliance with U.S. regulations. The University’s Export Control Policy provides guidance to the university for complying with U.S. export control regulations when engaging with international persons/entities both on campus or abroad. 

Which SBU offices can assist with international visitor reviews?

  • Visa and Immigration Services is the University’s resource for faculty and departments that want to host international scholars.
  • Research Security Program is the University’s resource for faculty and departments to assist with compliance with U.S. export controls regulations and other U.S. national security regulations/guidance. 

What should a host consider when they are thinking about hosting an international visitor? 

  • How do you know the visitor; and
  • Why do they want to come; and
  • Who is the person; and
  • Who is their employer/home institution; and
  • Are they a visiting postdoc or student: and
  • What is the source of their funding for the visit: and
  • Would their actual or potential visa status support the purpose of their visit; and
  • What information/items would they have access to; and
  • Does the host have, or anticipate to apply for, federal funding; and
  • Does anything about the visitor or their visit raise any red flags?

 

International Visitor Reviews 

Does anything about the proposed visit or visitor raise any red flags?

The very first thing to consider is whether there is anything about the international visitor or visit request that raises any red flags.

  • Appears to be a mass email or comes to you through a social media account (e.g., LinkedIn).
  • Asks for information about your research (e.g., data, techniques, or other non-public information).
  • Requests participation in a sensitive area of research (export controlled, national security, or U.S. competitiveness area (see U.S. Government’s Critical and Emerging Technologies for examples).
  • Asks to come participate in research that is not related to their background.
  • Asks about resources that would be available to them (e.g., equipment, software, materials, technical information that may be export controlled).

How do you know the visitor?

If the international visitor is not known to the host (e.g., current collaborator, previous student, postdoc, colleague) then the host should understand why that visitor wants to come to SBU, how that visitor found them, and if it is a legitimate visitor.

Emails from persons not known to you should be carefully reviewed if you plan on considering the request.  Ask the Research Security Program for assistance.

Why do they want to come?

It is important to know why an international visitor wants to come to SBU. The “why” or the purpose of the visit should make sense. The international visitor’s education, expertise, publications, and background should match the purpose of the visit.

Understanding “why” also helps to determine what additional reviews may need to be completed (e.g, export controls, data access/IT considerations, sponsor restrictions). Be sure to read the case studies later in this newsletter. 

  • Resource: Potential interview questions are provided at the end of this Newsletter.

Who is the person and their employer?

Are they or their home institution listed on any  U.S. government restricted/denied list? The federal agencies maintain lists of "restricted parties". Restricted Parties (aka denied or prohibited parties) are persons or entities (i.e., companies, universities, nonprofits, non U.S. government agencies) that are either prohibited or restricted in some manner from receiving non-public information and/or items.

Are they a visiting postdoc or student?

International visitors that are postdocs or students require additional considerations. In these instances, the host should also consider the postdoc or student’s supervisor and the type of research/scholarship conducted.

  • Hosts should conduct reviews to screen for restricted parties for supervisors when the international visitor is a postdoc or student.  Follow the guidance on the Export Controls website for assistance with this screening. 
  • Hosts should consider what information an international visitor may bring back to their supervisors. What does their supervisor expect them to share?

What is the source of the international visitor’s funding?

International visitors, especially those coming to the university as visiting scholars, must have funds to support their visits. Hosts should ask the international visitor for the source of funding for the visit.

  • Hosts should conduct reviews to screen for restricted parties for the persons/entities supporting the visit. Follow the guidance on the Export Controls website for assistance with this screening. 
  • Hosts should also consider what obligations the international visitor would have to the source of their funding.  What does the entity or person paying for the visit expect in return?  Are there any red flags or inappropriate expectations for the visitor?

Is the international visitor’s visa status appropriate for the purpose of the visit?

International visitors that are in the U.S. can partake in activities that are allowable/approved by their visa. There are different types of visas and visa authorizations and they provide for different types of activities (e.g., B-1,J-1, Visa Waiver).

What information/items will the host provide access to?

Most international visitors come to SBU to participate in fundamental research or educational activities.  However, they may still have access to confidential information or export controlled equipment, materials, software or technical data. Sharing may be prohibited or require an authorization from the U.S. government or third-party.

Consider the following examples that require further review:

  • Third-party software, materials, technical data subject to confidentiality and/or limits on sharing/use (whether verbal or written) may be export controlled. 
  • Non-public vendor technical information, such as specs, manuals, blueprints may be export controlled. 
  • Access to research results and/or meetings where sponsor approval prior is required prior  to publication. Access to data that a researcher is intentionally holding confidential from public release. These are export controlled until such information is made public.
  • Sensitive or export-controlled research data and/or meetings where foreign national access is restricted. Including cases where a sponsor pre-approves individuals for participation in a project.  
  • Physical access to export controlled items. In some cases, a person may receive export controlled technical data (deemed export) through simple access (or sight) of an export controlled item. 

How do you know if you have export controlled equipment, materials, software, or technical data?

Who can help you determine if access to the export controlled equipment, materials, software, or technical data is allowable?

The export control regulations can be complicated. Non U.S. person access to export controlled equipment, materials, or technical information depends on the export classification of the thing being shared in conjunction with the country of destination (the non-U.S. persons country of citizenship). 

Does the host have, or anticipate applying for, federal funding?

Hosts should be familiar with the policies and processes of their federal sponsors pertaining to international collaboration and international components of projects. 

International visitors participating in federally funded projects:

  • May require prior sponsor approval.
  • May require reporting to the sponsor as other resources/support.

Hosts with federal funding should be familiar with the federal sponsor agency's international risk assessment posture and review process.

Case Studies 

Case Study: International visitor attending an open lecture series. 

Lecture series are generally open to interested individuals.Participation in open lecture series generally do not include any research, scholarship, or access to non-public facilities or information.

What should be done:

  • If the university is supporting a visa request then restricted party screening of the attendee and their home institution.
  • Notice to presenters that the lecture is open and that non-public information should not be shared.  

Case Study: International visitor attending a workshop that requires registration and will provide demonstration of non-public technology.

A workshop that requires registration may still be considered open - but if the registration is being requested for the purposes of checking credentials, nationality/citizenship, or blocking a group from attendance that workshop would not be considered open.  When workshops are closed there are additional reviews for international visitors/attendees.

What should be done:

  • Review of the “why” they want to attend. Do they meet the criteria?
  • Restricted party screening of the attendee and their home institution.
  • Export control evaluation of the non-public technology that will be shared.
  • Determination of any required U.S. government authorizations to share the non-public technology with international visitors (or international attendees). 

Case Study: International visitor delegation attending a meeting with university leaders and touring open campus areas.

Meetings between international delegations and university leaders most often include conversations around general concepts, public information, and discussion of future collaborative efforts. As long as these meetings and tours remain limited to publicly available information and spaces.

What should be done:

  • Restricted party screening of the attendee and their home institution.
  • Institutional evaluation of whether the potential collaboration would fit within the university mission and evaluation of any institutional risks/benefits.

Case Study:  International collaborator visit to a research laboratory.

Most often international visitors come as visiting scholars to collaborate on fundamental research (meant to be publicly disseminated) or scholarly publications. However, there may be proprietary or export controlled information, equipment or materials. Restrictions (verbal or written) from sponsor(s) about access to a project or data also need to be considered when they are present.

What should be done:

  • In this case, you would want to make sure to review the potential visit with the guidance provided in this Newsletter!

Case Study:  International visitor coming for a lab tour.

Laboratories are not generally open to anyone. Sometimes laboratory tours are offered to groups such as: international delegations, the press, potential commercial partners, vendors and/or employees. Some laboratories, or even office spaces, contain proprietary or export controlled information, equipment or materials. 

What should be done:

  • Review of the “why” they want to have a lab tour? Does it make sense for their role?
  • Restricted party screening of the attendee and their home institution.
  • Export control evaluation what an international visitor will have access to during a lab tour (e.g., export controlled equipment, materials, technical data, manuals)
  • Determination of any required U.S. government authorization for the international visitor to access export controlled these items with international visitors or removal of the export controlled items from the lab.

Suggested Interview Questions for International Visitors

1. Why did you choose Stony Brook University (SBU)?

2. Why do you want to pursue this type of research or training here at SBU?

3. Why did you choose to work with my lab/team specifically?

4. How did you find out about my research or lab?  (e.g., conferences, meetings, collaborators, literature, Internet, etc.)?

5. Who is paying for you to come here and sustain you during your requested visit?  What are your obligations back to them upon completion of your visit?

6. What type of professional affiliations do you maintain in your country, which are directly relevant to your proposed visit?

7. Are you currently or have you anytime in the past been a member of a foreign talent program?

8. What are your plans upon completion of your visit?  Do you plan to go back to your home country?  Do you wish to stay here in the United States?  What will you do with the knowledge you will gain?

9. Are you or your family in any way affiliated with your home country’s government or its military?  If so, do they have any influence in the research or training you wish to obtain (e.g. are they paying, sending you to study a specific field)?  (Certain fields should raise red flags - energy, nuclear, biological, aerospace etc.)

10. Has anyone ever approached you to perform tasks that are not related to your area of education or research?

11. Does your home country have any influence in the type of research you are performing/conducting?