Appendix A: SUNY I-RISK Quick Guide
Appendix B: Risk Classification and Examples
Appendix C: Oversight & Governance Model
SUNY has established a new, systemwide process to respond to the Statewide Policy on Meetings with Foreign Government Representatives (the "State Policy").[1] The purpose of this process is twofold: to safeguard New York’s security and intellectual property interests while ensuring that academic and research engagement can continue efficiently and without unnecessary administrative burden.
The following documents are provided to help contextualize the concerns and risks this guidance and process herein seeks to address.
All state-operated SUNY campuses will follow a three-tiered model to address risk associated with engagements based on (a) the type of activity the participants are engaged in, (b) the subject matter of the engagement, and (c) the country or countries represented by foreign representatives at the engagement.
[1] New York State Executive Chamber, Statewide Policy on Meetings with Foreign Government Representatives (Memorandum dated Sept. 2, 2025).
As a threshold matter, SUNY recognizes that certain activities are routine functions in the normal course of academic, research, and administrative operations. These activities do not, by themselves, trigger escalation or review under this framework and may be handled at the campus level, regardless of country, provided they do not involve sensitive subject matter, government-linked engagement, or other risk-enhancing characteristics described below.
Routine academic activities include:
Activities that fall within this category proceed under normal campus oversight unless and until their nature changes. When the scope of an activity expands, discussions begin regarding renewal or renegotiation of an agreement, or new access, subject matter, or government‑linked involvement is introduced, the activity should be reassessed under this framework.
Tier 1 engagements are routine, day‑to‑day, international activity that takes place across our campuses as part of normal academic, research, and administrative operations, such as conference attendance, student exchanges, research collaborations (formal or informal), or standard student recruitment and outreach. These activities are generally low risk and do not, by themselves, warrant System‑level submission. These routine activities do not require submission to SUNY System pursuant to this guidance, but must be recorded and retained in accordance with existing campus recordkeeping practices at the campus level. Campuses are expected to maintain a log of Tier 1 activities and their own internal records through their existing travel, research, or international‑program approval, tracking, or registry processes and systems.
Campuses should use existing tracking or data‑capture mechanisms solely for Tier 1 activities. Records may be maintained at an aggregate or programmatic level consistent with existing practice.
Tier 2 engagements are those that rise above routine engagement and warrant System‑level visibility, but that do not present unresolved security risks. This includes formal meetings with national‑level diplomats or provincial leaders, initial or substantive discussions and communications related to new or revised agreements involving academic programming or research conducted jointly with non‑U.S.‑based entities, and joint funding discussions with foreign public sources that are not broadly available to U.S. institutions. Campuses will submit these activities using the online SUNY International Engagement Form. Each submission will automatically populate a real‑time tracker managed by System Administration’s Office of Global Affairs. Tier 2 items are not intended to require active review, and campuses may proceed with the activity following local approval unless contacted by SUNY System for clarification or follow‑up. Submissions are screened to ensure proper categorization; otherwise, they are logged for transparency, pattern analysis, and State reporting, and may be sampled periodically or flagged if specific questions arise.
To reduce duplicative reporting and administrative burden, SUNY System may approve campus-based Tier 2 tracking or approval mechanisms as functionally equivalent to submission through the SUNY International Engagement Form, provided such mechanisms capture the required information elements, allow System level access for visibility and reporting, and support aggregate analysis and State reporting requirements. Campuses seeking to rely on an approved alternative process must coordinate with SUNY Office of Global Affairs to ensure continued alignment with this framework.
Tier 3 engagements involve designated countries of concern in combination with risk enhancing characteristics, or sensitive or dual use subject matter regardless of country. Tier 3 classification reflects elevated risk requiring structured review, not a presumption of prohibition. Entry into Tier 3 initiates a structured review process intended to assess risk, apply mitigations where appropriate, and determine whether escalation beyond SUNY is necessary. Tier 3 indicators are used to identify engagements that warrant closer scrutiny; the presence of one or more indicators does not, by itself, determine an outcome.
For purposes of identifying Tier 3 indicators, countries of concern are those appearing on applicable federal or State sanctions, restrictions, or travel advisory lists. For purposes of this guidance, these currently include Cuba, Iran, Russia, North Korea, China, Ukraine (Crimea, Luhansk, and Donetsk only), Venezuela, Belarus, Syria, Balkans, Burundi, Democratic Republic of the Congo, Lebanon, Libya, Somalia, South Sudan, Yemen and Zimbabwe. These lists and advisories may change periodically and should be monitored accordingly.
Topics of concern, regardless of country, include activities or engagements involving the following sensitive or dual use subject matter areas, such as:
When Tier 3 indicators are identified, review of the engagement begins at the campus level. Campuses will continue to conduct local prescreens prior to submission to SUNY System to verify completeness, consistency with campus conflict of interest and travel policies, and alignment with applicable federal and campus export control requirements and institutional expectations. Campuses may deny or return submissions locally where an engagement cannot be supported under existing policies and, where appropriate, may propose risk mitigations or conditions as part of their submission. The SUNY Research Foundation maintains records of externally sponsored projects involving export controlled or managed research and will coordinate with SUNY System on any Tier 3 submissions that intersect with those areas.
When a Tier 3 engagement is submitted to SUNY System, it is reviewed through the SUNY International Risk Working Group, which may clear the activity, request additional information, recommend mitigations or conditions, or escalate the engagement to the New York State Division of Homeland Security and Emergency Services where unresolved risk remains. Where risks are understood and appropriately mitigated, Tier 3 engagements may be reviewed and cleared within SUNY.
SUNY System will coordinate with appropriate State partners as required and will ensure that relevant outcomes are documented and communicated to campuses, with periodic, aggregate summary reporting to support State‑level visibility and coordination.
In practical terms, this framework means that the majority of SUNY’s international activity, including routine travel, open academic conferences, and ongoing academic partnerships, will continue to be managed through established campus processes. Higher risk or higher profile engagements are made visible to SUNY System and, where appropriate, to State partners through a single, streamlined channel.
The three-tier model enables SUNY to meet the requirements of the State Policy while minimizing redundant outreach, reducing institutional risk, and strengthening systemwide compliance without impeding academic collaboration or routine scholarly exchange.
For activities that meet the criteria for submission under this guidance, state operated campuses should submit the SUNY International Engagement Form at least seven business days in advance of individual meetings, or fourteen days before the first event in an ongoing series. For existing partnership agreements, submissions should occur at the initiation of renewal or renegotiation discussions.
Once operational, this process will provide an integrated, risk-based approach to international engagement that protects academic freedom and institutional integrity, while reinforcing SUNY’s commitment to transparency, security, and responsible global engagement.
Questions about implementation or next steps may be directed to IRISK@suny.edu.