/Office for Research and Innovation
Research Security

 

Foreign Sponsors

Stony Brook University (SBU) faculty who seek funding from foreign sources should be mindful of how export controls can apply. 

Restricted Party Screening Requirement

Foreign sponsors that are a Restricted Party require prior approval. 

The U.S. government maintains lists of entities and persons who are restricted and/or denied certain transactions.  

It is an elevated risk to SBU and/or the individual to partake in research and/or provide research related services to these entities and persons. Contact the Research Security Program before beginning discussions or starting a project that is funded by, or for the benefit of, a Restricted Party.

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

In most cases, the sponsors in myResearch are not on any Restricted Party Lists.  However, these lists are updated on an ongoing basis.  Screenings should be done when engaging with foreign sponsors for the first time. 
Before You Conduct Research/Services for a Foreign Sponsor

Whenever your research will be funded by a foreign sponsor, take note of the following:

Potential Red Flags - How well do you know the potential sponsor?

  • How well do you know the customer/sponsor?  Have you worked with them before or are they "cold calling"?
  • Why do they have an interest in your research?  Is it relevant to their business?  Are they transparent about this?
  • Do they show an interest in sensitive topics that are outside the scope of your research?
  • Do you notice any other red flags or suspicious elements?

 Fundamental Research 

Any and all projects funded by a foreign sponsor must be for Fundamental Research. Research results that do not qualify as Fundamental Research may be subject to export controls restrictions and could require a US government license in order to be delivered to a foreign sponsor.

Restricted Parties

Per the Policy on International Engagements you will need prior-approval from the Office of Research Security if your foreign sponsor is a restricted party.  Always perform screening and due diligence on potential sponsors in foreign countries before working with them.

Military (or Foreign Government) Sponsors

If the foreign sponsor is a military unit or military organization in another country, you may be providing a Defense Service by performing the research.  Such activities always require US Government pre-approval.

Generally Prohibited Activities with Foreign Sponsors

If the research is in any of the following areas (even if publishable Fundamental Research), it will generally be prohibited:

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

Shipments, Travel, and Transfer of Data/Software/Materials

Any shipments or material transfers to the foreign sponsor need to be evaluated for export controls as licenses may be required from the U.S. Government.

Be mindful of travel-related export controls restrictions that could apply when visiting a foreign sponsor.

Be cautious about sharing any unpublished information with any foreign sponsor or entity.

Return to the Guidance & Procedures for Export Control Compliance