/Office for Research and Innovation
Research Security

 

International Collaborations

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.

Request an Export Review of a Collaboration (NetID login required) 

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. 

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 Parties 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

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 Department of Treasury, Office of Foreign Asset Controls places restrictions on certain persons, entities, and countries.  

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 MUSTconsult with the Export Control Compliance team before conducting any activities.  

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 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 Export Control Compliance team to evaluate for export control and IT compliance. 

Fundamental Research Overview

The export control regulations also place restrictions on specific activities of U.S. persons that could harm national security, even if an export is not actually occurring per se.

Generally speaking, providing support to foreign persons or entities in the following areas are prohibited:

  • Nuclear explosive devices
  • Missiles, rocket systems, and unmanned aerial vehicles
  • Chemical or biological weapons (including plants for their production)
  • Military Intelligence 

Note that “support” is very broadly defined  and could include providing a foreign entity or person with the results or findings of Fundamental Research if it is in furtherance of one of these areas listed above.

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 Guidance

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.

International Transfers: Shipments, Hand-Carry, and Electronic Transmissions Guidance

Export Review Examples 

Here are examples of collaborations that would require an export control compliance review. 

Due to comprehensive sanctions on Iran, this activity would need a specific license from the Office of Foreign Asset Controls.  A specific license must be obtained through the Export Control Compliance team.  

Plasmids, while not being harmful or infectious in of themselves, can be subject to export restrictions and should always be reviewed by the Export Control Compliance team before shipment.

The topic of the publication and any collaborative efforts towards the project must be Fundamental Research. 

In addition, there are other considerations if the colleague is from a university listed on a Restricted Party List or is in an embargoed country. Interactions in these instances must be reviewed by the Export Control Compliance team.

Research Security Review 

International collaborations must also be reviewed for Research Security concerns.  Export control compliance is just one part of a comprehensive review.   Review the Research Security Program's International Collaborations Guidance.

Agreements 

SBU faculty and staff are not permitted to complete (i.e., sign) any agreement with a foreign entity.  Review this chart for the appropriate agreement and office for your activity.   International agreements must be reviewed by the Export Control Compliance team for any export licensing requirements.

Return to the Guidance & Procedures for Export Control Compliance