International Collaborations

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Stony Brook University (SBU) faculty, staff, and students are encouraged to participate in international activities, as these may promote the creation of knowledge and enrich learning experiences.  These activities can be engagements with international persons, labs, institutions, or other entity types.   International research activities may be performed in the U.S., outside of the U.S., or a combination.

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Restricted Party Screening Requirement

International collaborations enriches SBU community’s intellectual and research endeavors, international connections, and global perspectives. However, these collaborators may be knowingly or unknowingly acting on behalf  an entity of concern. 

Researchers, as well as faculty and staff, engaging in international collaborations are required to complete a Restricted Party Screening.    

• Restricted Party Screening: what it is and how to complete it.

  The U.S. government maintains lists of entities and persons who are restricted and/or denied certain transactions.  This includes the recent "1286 List" - Restricted Party Overview

  All  foreign person and entities must be screened for inclusion on any of these lists prior to engaging in activities.  If they appear on one of these lists you must contact the Research Security Program before engaging in any activities or invitations. 

  How to conduct a restricted party screening using Descartes Visual Compliance software

Research Security Review

In addition to addressing concerns related to restricted parties, other regulatory requirements, such as access to export-controlled information, access to intellectual property, and potential undue foreign influence concerns must be considered and reviewed in balance with the benefits of  the international collaboration.  

Researchers, as well as faculty and staff, should review the below  general guidance for considerations when engaging in international collaborations. 

• How is the collaborator known?

  Be aware of potential Academic Solicitation which may include requests from U.S. persons, or from foreign nationals located in the United States or abroad, and may consist of:

  • Unsolicited applications or requests for undergraduate, graduate, postgraduate or other research positions.
  • Unsolicited requests for access to research papers or other research-related publications or documents.
  • Unsolicited requests for assistance with or review of thesis papers, draft publications or other research-related documents.
  • Unsolicited invitations to attend and/or present at international conferences.
• What Is and Is Not Considered Fundamental Research?

  Fundamental Research

  • Fundamental research means research in science, engineering or mathematics, the results of which ordinarily are published and shared broadly within the research community, and for which the researchers have not accepted restrictions for proprietary or national security reasons.

  Important: Fundamental Research is invalidated when restrictions on free dissemination of research or research methods used during the research are agreed to in a contract or verbally with a sponsor. 

  Non-Fundamental Research

  • Proprietary research, industrial development, design, production and product utilization the results of which are restricted, and
  • Government funded research that specifically restricts the outcome for national security reasons are not considered fundamental research.

  Important:

  • Non-fundamental research should not be conducted outside of the U.S. without a Research Security Program review. 
  • Non-fundamental research must be reviewed by the Research Security Program to evaluate for export control and IT compliance. 

  Fundamental Research Overview

• Is the collaboration in a field of Critical and Emerging Technologies?

  The federal government maintains a list of critical and emerging technologies that are potentially significant to U.S. national security.

  Conduct of research in these areas with an international partner should be reviewed by the Research Security Program.

  Federal Resource:  Critical and Emerging Technologies List Update (February 2024); Fast Track Action Subcommittee on Critical and Emerging Technologies of the National Science and Technology Council.

• Is the collaborator or the collaborator's home institution in a Country of Concern?

  The federal government has identified China, Iran, Russia and North Korea as Countries of Concern.   

  There are additional considerations when collaborating with individuals/entities in Countries of Concern contact the Research Security Program for a review of the collaboration and discussion about any potential risks or restrictions. 

• Does the collaboration include an appointment (of any kind) at an international institution for an SBU person?

  Faculty members who are offered appointments at other academic institutions are required to follow the Approval Process for Faculty Members who are Offered Appointments at Foreign and Domestic Institutions.   Faculty should carefully review the terms for external appointments, especially if they have federally sponsored research to ensure that the terms of the agreement are not in conflict with their SBU responsibilities.  Examples of potential conflicts include: 

  • time commitment  
  • scientific overlap 
  • intellectual property assignment 
  • attribution in publications

  Faculty should understand the characteristics of foreign talent recruitment program (FTRP).  Most federal sponsors prohibit a principal investigator or key personnel from participation in a malign foreign talent recruitment program (MFTRP) and/or consider participation in any FTRP when making award determinations. 

• Does the collaboration involve visitors coming to campus?

  Additional reviews may be necessary to host a visitor on-campus.  Review the information on International Visitors .

• Does the SBU collaborator have federal funding?

  U.S. federal  agencies are increasing efforts to identify and counter undue foreign influence in federally-funded research and have implemented a variety of policies and processes for these purposes.  Faculty and staff should understand how federal funding agencies will review and consider their international relationships.  Review the information on Federal Sponsor Risk Reviews. 

• Will there be co-authored publications?

  Publications should accurately reflect affiliations, contributions and support.  U.S. federal agencies also monitor publications to ensure that foreign components, international collaborators and funding support have been properly reported both in the manuscript and to the agency. Review the Recommendations on Authorship from the Provost's Office.

  Note: Several SBU departments also have authorship guidelines for their area. 

Export Control Review

Researchers , as well as faculty and staff, engaging in international collaborations have an obligation to be aware of export restrictions applicable to the conduct of international collaborations.  The Export Control Compliance team can provide support with potential export controls issues for international collaborations. For additional information review the International Collaboration Guidance.

• Is the collaborator in an embargoed or sanctioned country?

  Beyond Countries of Concern (China, Iran, North Korea, and Russia), the Department of Treasury, Office of Foreign Asset Controls places restrictions on certain persons, entities, and countries.  Full list available here

  If the collaboration will be with an individual or entity in an embargoed country, i.e., North Korea,  Cuba, Iran , Russia, Syria, Crimean Region of Ukraine, Luhansk Region of Ukraine, or Donetsk Region of Ukraine, the faculty member or student's faculty advisor MUST consult with the SBU Export Control Compliance team before conducting any activities.   

  Remember to review the International Collaboration Guidance for additional information on export controls and embargoes/sanctioned countries.

• Will the SBU collaborator (or their staff) share information?

  If the collaboration includes the sharing of information that is not Publicly Available, in the Public Domain, or Published then that information is considered proprietary and needs to be reviewed for export control determination.  

  • International Transfers: Shipments, Hand-Carry and Electronic Transmissions
  • Review International Travel for disclosure of information while outside the U.S. 
• Will the SBU collaborator (or their staff) ship or hand-carry any items as part of the collaboration?

  If the collaboration includes the shipment or hand-carry of any tangible items (i.e., equipment, materials, documents, supplies) then those items should be reviewed for export control determination. Review the International Transfers: Shipments, Hand-Carry and Electronic Transmissions

Federal Sponsor Requirements

Researchers with federal funding must understand when collaborations need to be disclosed to and/or require approval from a federal sponsor.  Disclosure and prior approval requirements may vary among federal sponsors. 

• Does the collaboration need to disclosed to a federal sponsor?
  Disclosures to federal sponsors may be required depending upon the detail of the international collaboration.  Review the Sponsor Requirements:  Biosketch, Current & Pending, & Other Support information.
• Does the collaboration require prior approval from a federal sponsor?

  Consult with the Office of Sponsored Programs before including any non-U.S. entities on federally sponsored projects as these collaborations may require prior sponsor approval. 

Other Campus Requirements

Commitment of effort or resources should have the appropriate campus approval.  These approvals may include any number of campus areas, including department, school/college,  Provost/EVP Health Sciences,  OVPR and/or other administrative areas (e.g. procurement, accounting, facilities).

Remember:  Faculty and staff are not permitted to complete (i.e., sign) any agreement that names Stony Brook University or The Research Foundation for SUNY or commits its resources.  

• When is an agreement required?
  • Commitment of SBU or RF resources
  • Commitment of effort
  • Specified research project (funded or unfunded)
  • Development of intellectual property
  • Subawards (incoming or outgoing)
  • Purchasing or leasing of equipment

  When Should an Agreement be Considered? 

  • Transfer of materials (Material Transfer Agreement)
  • Exchange of confidential information (Confidentiality Agreement/Non-Disclosure Agreement)
  • Transfer of data (Data Use Agreement)
• Who can commit campus resources?

  Commitment of effort or resources should have the appropriate campus approval.  These approvals may include any number of campus areas, including department, school/college,  Provost/EVP Health Sciences,  OVPR and/or other administrative areas (e.g. procurement, accounting, facilities). When an agreement is contemplated, these approvals are obtained during a campus review process.   For research collaborations these approvals happen through the routing process in myResearch Grants.   

• Does the collaboration include a gift?

  Gifts may be in the form of donations of money, property, or resources with no clear expectation of direct benefit to the donor.   

  All gifts to SBU should be reported to ensure proper review and management. 

  • Gift Policies, Stony Brook Foundation 
  • Gifts for Research, Office of the Vice-President for Research
  • Gifts from Countries of Concern or Restricted Parties (or their subsidiaries/U.S. counterparts) must be reviewed by the Research Security Program. 
  • If gift funds are used to support sponsored research there may be additional reporting to the research sponsor (e.g. disclosure of other support to the National Institutes of Health). 
• Are there international data compliance laws?

  International activities that involve the collection, use, or transfer of personal data may be subject to additional regulations (e.g., European Union's General Data Protection Regulation,  China's Personal Information Protection Law).

  Important: SBU is not currently not able to comply with GDPR regulations and similar types of regulations from other countries.  

• Does the collaboration include human subjects?

  Human subjects research that takes place outside of the U.S. requires additional information and assurances during the IRB approval process.  Data that is collected outside of the U.S. may be subject to country specific or international laws (see Data Compliance above).  Human Subjects Standard Operating Procedures (Section 17.3) and GDPR and Human Subjects Research information from the Office of Research Compliance.

• Does the collaboration include animals?

  The Division of  Laboratory Animal Resources routinely assists researchers in the importation and/or exportation of animals from other institutions (i.e. non-vendor sources). It is important for the researcher to plan ahead since there are numerous steps that have to be completed by both the sending and receiving institutions.