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International Research Activities

Stony Brook University remains committed to the principles of academic freedom and the open exchange of knowledge, which serve as the bedrock of research and scholarship.  Our faculty and students are encouraged to participate in international collaborations, as these may promote the creation of knowledge and enrich learning experiences.  However, such international research 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.

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.

Below are considerations* for engaging in international research activities. 

*some of the considerations listed below apply to research projects even when there is no international collaboration.


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
  • exchange of confidential information
  • transfer of data

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.  Click here to find the appropriate campus office for your agreement.


Approvals

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.   

OVPR Resource:  About myResearch Grants

Note: Other types of approval processes are referenced on this page, however, this does not represent a complete list of all types of campus approvals or processes.   


COST Sharing and Matching

Federal grant funds cannot be used for cost-sharing or matching.   If you are committing non-reimbursed effort or in-kind materials or services to a project then the non-federal source needs to be identified.  If there is an agreement commiting these resources they will need to be recorded. 

OVPR Resource:   Cost Sharing and Matching


Disclosure

International activities must be properly disclosed in your Disclosure Profile in myResearch Conflict of Interest and to federal sponsor agencies as required by  grant application guidelines and terms of awards.

OVPR Resources: Conflict of Interest and/or Commitment and Federal Sponsor Requirements:  Biosketch, Current & Pending & Other Support


embargoes/Sanctions

International activities, of any type, with an embargoed or sanctioned country (e.g. Cuba, Iran, Russia, North Korea, portions of Ukraine)  require a U.S. government authorization or a documented review for why a U.S. government general authorization was applied. 

OVPR Resource: Embargoes and Sanction Programs


emerging technologies

The federal government maintains a list of critical and emerging technologies that are potentially significant to U.S. national security.    If you are contemplating a research project with an international partner in one of these areas contact the Director of Research Security.

Federal Resource:  Critical and Emerging Technologies List Update (February 2022); Fast Track Action Subcommittee on Critical and Emerging Technologies of the National Science and Technology Council


Export Controls

Export controls apply to physical shipments and release of technical information outside of the U.S. as well as release of technical information inside the U.S. to a foreign person.   All campus members are responsible for complying wth SBU's Export Control Policy (P212) and understanding the export control guidance and procedures outlined in the policy.  

Export controls may impact international collaborations, conferences/seminars, shipments, travel and visitors.  Whenever you are engaged in an international activity be sure to review the appropriate guidance documents or contact the Director for Research Security. 

OVPR Resource: Export Control Guidance and Procedures


External appointments

Faculty members who are offered appointments at other academic institutions are required to follow the Office of the Provost's procedures.   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 government talent recruitment program.  In some cases federal sponsors prohibit a PI's participation in a foreign government talent program or consider these external appointments when making award determinations. 

OVPR Resource: Biosketch, Current & Pending & Other Support


foreign components

Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports.    Foreign components are defined "as any significant scientific element or segment of a project outside of the United States  it includes performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or  performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended" (NIH - NOT-OD-19-114).  

Other federal agencies have similar language and requirements.

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

OVPR Resource: Questions about Foreign Components  - contact your OSP Specialist 


Foreign corrupt practices act (U.S. law)

The Foreign Corrupt Practices Act (FCPA) is US law that makes it illegal to provide anything of value to a foreign government official or political party in order to obtain an unfair advantage.  It is also illegal to provide anything of value to a third party with knowledge that the benefit will be provided to a foreign official, party, or candidate.

International Trade Administration Resource: U.S. Foreign Corrupt Practices Act


fundamental research

International research activities must be for the conduct of fundamental research.

OVPR Resource:  Fundamental Research 

Bureau of Industry and Security Resource: "What is considered fundamental research under the EAR"  and "What types of research are NOT considered fundamental research under the EAR". (Export Administration Regulations (EAR) FAQ (page 4 of 15))

Note: If the research project involves items/technical data subject to the International Traffic in Arms Regulations (ITAR) as the subject of the research or for use in the research a consultation with the Director of Research Security is required.


gifts 

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 Stony Brook Foundation to ensure proper review and management.   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).   

Stony Brook Foundation Resource:   Gift Policies 

OVPR Resource:  Gifts for Research


Guests/visitors (international)

Faculty and staff inviting or hosting visiting researchers, scholars, and interns, paid or unpaid, shall obtain from their respective department a formal invitation letter, following the prescribed format appropriate for the category of guest/visitor, describing the terms and purpose of the visit.  All campus members are responsible for complying wth SBU's Guest/Visitor Policy (P601).

Visa and Immigrations Services Resource:   J-1 Student Intern & Scholar 

Note: When inviting or hosting visitors not in a J-1 status (i.e B-1/B-2, Visa Waiver Program) should consult Visa and Immigratons Services.  


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. 

OVPR Resource: Human Subjects Standard Operating Procedures (Section 17.3)


intellectual property 

An invention may be any new and useful process, machine, composition of matter, life form, article of manufacture, software, trademark, copyrighted work, or tangible research property. In order for an invention to be patentable it must be useful, it must be new and original, and it must be non-obvious.  

New inventions should be disclosed to Intellectual Property Partners before publication or dissemination of research results.  

SUNY Resource:  SUNY Patent, Inventions and Copyright Policy

OVPR Resource:  Disclose a New Technology  and Frequently Asked Questions


publications

Publications should accurately reflect affiliations, contributions and support.   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. 

Office of the Provost Resource: University Recommendations on Authorship

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


Research Data

Data Use Agreements (DUA) are used to transmit, receive or exchange non-public data to/from an external party.  DUAs place restrictions on the use, disclosure, confidentiality or publication of data.    

DUAs for incoming data from a non-U.S. entity or of a non-U.S. origin may contain additional data privacy requirements (e.g. European Union's General Data Protection Regulation,  China's Personal Information Protection Law) that pose signficant compliance challenges.    Faculty/staff should work with the appropriate campus offices to make sure that they can comply with transfer, storage and protection of these data. 

DUAs for outgoing  human subjects data or other non-public data to a non-SBU party should be requested from the appropriate campus office (see OVPR Resource below).

OVPR Resource:  Data Use Agreements

SBU Libraries Resource:  Scholarly Communication 


Research Materials 

Material Transfer Agreements (MTA) are used to exchange research materials with an external party.  MTAs place restrictions on the use,  confidentiality or publication of the research materials and may also provide a mechanism to receive compensation for the materials to cover the cost of creation and/or shipment. 

Research materials can include a range of incoming or outgoing items, for example - prototypes, algorithms, plasmids, mouse models - and may be subject to government regulations and sponsor and/or campus policies.  Research materials may come with restrictions on the use, reporting requirements,  or intellectual property rights. 

At a minimum MTAs should be requested when researchers want to protect the manner in which in their research materials are used.   MTAs should be used for transfer of any human subjects materials.  

OVPR Resource:  Material Transfer Agreements


Restricted Party Screening 

The U.S. government maintains lists of entities and persons who are restricted and/or denied certain transactions.  All  foreign person and entities should be screened for inclusion on any of these lists prior to engaging in activities. 

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


scientific overlap

There should be no scientific overlap between the research being conducted with an  international collaborator and a federal award unless the collaboration has been approved by the federal sponsor. 

Scientific overlap occurs when (1) substantially the same research is proposed in more than one application or is submitted to two or more funding sources for review and funding consideration or (2) a specific research objective and the research design for accomplishing the objective are the same or closely related in two or more applications or awards, regardless of the funding source (NIH Just-in-Time Procedures). 

OVPR Resource: Questions about Scientific Overlap  - contact your OSP Specialist 


travel

Faculty, staff and students may travel internationally for many different reasons.  The OVPR has created resources to assist with international travel.  If sponsored funds are used for travel, the travel must be appropriate for the award.   If travel is being paid by a third party it must be disclosed in your Disclosure Profile in myResearch Conflicts of Interest.

OVPR Resource:   Research Travel Guidance,  How to Review your International Travel for Export Compliance