Who does this apply to? This guidance applies to anyone representing SUNY in an academic, research, administrative, or professional capacity when engaging internationally. This includes SUNY faculty, staff, graduate students, postdoctoral researchers, and SUNY Research Foundation employees when their activities are connected to their SUNY role. The guidance applies based on the nature of the activity and representation of SUNY, not employment category or funding.
Does this apply to all aspects of SUNY staff lives or just their professional roles? This guidance applies only when an individual is representing SUNY or acting in connection with their SUNY role. SUNY does not regulate purely personal activities that are unrelated to SUNY responsibilities. However, individuals must continue to comply with existing campus, SUNY, and New York State conflict-of-interest and outside employment policies when applicable.
My PhD graduate student and postdoc are hired by the SUNY Research Foundation and supported 100% by a grant. Are they subject to this policy. Yes. Graduate students, postdoctoral researchers, and staff supported through the SUNY Research Foundation are covered when they are acting on behalf of SUNY or engaging internationally in connection with SUNY-supported work. Coverage is determined by representation and activity, not payroll source.
Does this guidance apply to academic collaborations that have already been approved or only new ones? It applies to both new and existing international engagements, partnerships, or structured activities. If an existing engagement or partnership activity involves a designated country, foreign government representative, government-affiliated institution, or sensitive or dual-use subject matter, it should be submitted so it is inventoried and reviewed under the current framework.
How does this relate to existing export control or conflict-of-interest policies? This guidance does not replace or supersede existing federal, State, or campus export control, conflict-of-interest, or research compliance requirements. Instead, it operates as an additional visibility and risk-screening layer for international engagements that meet the criteria described in the guidance. Campuses and individuals must continue to follow established export control and COI processes.
Is this a permanent or a temporary measure? This is a permanent process. SUNY will continue to update the guidance and associated procedures as federal and State requirements evolve, but the three-tier framework and risk-based approach are intended to be ongoing.
What exactly counts as a "meeting with a foreign government representative"? For purposes of this guidance, a "meeting" is a planned interaction, whether in person or virtual, conducted in a professional or institutional capacity with a foreign government representative. This includes formal meetings, delegation visits, invited talks, or organized discussions where the individual is acting on behalf of a foreign government, political party, or government‑affiliated institution.
Research interviews and data‑gathering interactions conducted as part of open, fundamental academic research are generally considered routine academic activity (Tier 1) when they are undertaken for scholarly purposes and do not involve sensitive or dual‑use subject matter, government sponsorship or direction, restricted access, or non‑public information. In these circumstances, submission to SUNY System is not required, and the activity remains under normal campus research oversight and applicable research ethics and human‑subjects requirements.
If an interaction goes beyond routine academic research, for example, if it involves formal engagement with senior government officials, government‑directed activity, agreement discussions, or sensitive or controlled subject matter, it should be assessed under the Tier 2 or Tier 3 criteria and submitted as appropriate. When in doubt, campuses may submit the engagement with explanatory context noted.
For Tier 2 and Tier 3 activities, does this apply to virtual meetings or only in-person visits? Does this relate to email correspondence related to agreements? The guidance applies to all meeting formats, including in-person meetings and virtual meetings, when the engagement meets the criteria described in the framework. Routine email correspondence related to existing agreements does not require submission unless the communication itself constitutes a planned meeting or triggers Tier 2 or Tier 3 criteria
What is considered a "foreign government–affiliated" institution? A foreign government–affiliated institution is any organization that is owned by, controlled by, or closely linked to a foreign government or political party. This can include public universities, state-owned enterprises, political party–affiliated organizations, media outlets, or other entities where government influence is present. Both public and private nonprofit organizations may qualify if such affiliation exists
Does this apply to private, nonprofit organizations in Tier 3 or only to public ones? It applies to both public and private organizations. A private, nonprofit organization may still be considered foreign government‑affiliated if it is owned by, controlled by, or closely linked to a foreign government or political party.
Campuses and faculty are not expected to conduct investigative or intelligence‑level assessments of potential partners. Rather, reasonable, good‑faith diligence, such as reviewing publicly available information about an organization's governance, funding sources, or stated affiliations, is sufficient at the campus level.
If an institution appears to be publicly funded, state controlled, or otherwise influenced by a foreign government, submission is required. If affiliation is unclear or information is incomplete, the engagement should be submitted with that uncertainty noted, so it can be reviewed and classified appropriately. When in doubt, submission is the correct path to ensure consistency and compliance.
What happens if we're unsure whether a partner institution is government-affiliated? If affiliation is unclear or information is incomplete, the engagement should be submitted with the uncertainty noted. SUNY System will review the information and classify the activity appropriately. When in doubt, submission is the correct path to ensure consistency and compliance.
What qualifies as a "country of concern"? Countries of concern are those identified based on applicable federal and State sanctions or restrictions lists. These countries receive additional attention under this guidance, but country alone does not determine risk or outcome. Most routine academic work may continue as usual, including in countries of concern, when the activity is open, transparent, and does not involve sensitive subject matter or other risk‑enhancing characteristics.
How often is that list updated, and who maintains it? The list of countries of concern is reviewed at least annually and updated as federal or State requirements change. Updates are coordinated centrally and shared with campuses so that faculty and staff are working from a consistent and current reference. Campuses are not expected to independently track geopolitical developments.
What are "topics of concern"? Topics of concern are areas that involve sensitive or dual‑use technologies identified under federal export control regimes, including items on the U.S. Munitions List and the Commerce Control List, as well as other sensitive areas described in the guidance. These topics warrant additional visibility because of the nature of the subject matter, but they do not automatically prevent an activity from moving forward.
How do we know if our project is dual-use or sensitive? Faculty and staff are not expected to make complex determinations on their own. In most cases, reasonable judgment based on the nature of the work, combined with existing campus resources such as research administration or export control offices, is sufficient. If an activity involves non‑public data, restricted access, or controlled technologies, or if there is uncertainty, submitting the engagement with brief context is encouraged so it can be reviewed and classified appropriately.
What activities require submission through the form? Academic, research, and co‑curricular activities require submission when they involve a designated country, a foreign government representative, a government‑affiliated institution, or sensitive or dual‑use subject matter as described in the guidance. Routine Tier 1 activities, as defined in this guidance, do not require submission. These submissions provide System‑level visibility for activities that rise above routine academic engagement and may warrant monitoring or review. If an activity meets one or more of the identified triggers, it should be submitted so it can be logged and classified appropriately; when in doubt, submission is encouraged.
What should we do if we are unsure whether an engagement requires submission or how it should be categorized? Submit the engagement and note the uncertainty. Submissions are screened to ensure proper categorization, and when information is incomplete or affiliation is unclear, submission with the uncertainty noted is the correct path so it can be reviewed and classified appropriately.
What activities are considered routine academic activity and do not require submission? Routine academic activity includes day‑to‑day teaching, research, and scholarly communication that is open, fundamental, and part of normal academic practice, such as attending open conferences, routine faculty collaboration, dissertation advising, study abroad administration, student recruitment, and standard academic communications with international colleagues. This does not mean logging every email, call, or message with a collaborator; ordinary correspondence and ongoing scholarly exchange do not require submission. Campuses retain flexibility to manage agreement discussions, formal government engagement, sensitive or controlled subject matter, or other risk‑enhancing characteristics through existing local processes, standards and safeguards continue to govern the protection of sensitive data.
Is travel funded by a grant treated differently from university-funded travel? No. The funding source does not change whether an activity needs to be submitted. If the engagement meets the criteria described in the guidance, it should be submitted regardless of whether the travel or activity is supported by a grant or by university funds.
Does all of this apply to work that is funded by US federal or other agencies? Yes. The funding source does not change whether an activity should be submitted. The determination is based on the nature of the engagement, who is involved, and the subject matter of the activity—not on the sponsor. SUNY does not expect individual faculty or principal investigators to interpret or explain this guidance to their funders; the framework is intended to provide internal visibility and coordination, and SUNY System will continue to work at the System and State level to align implementation with broader federal and State requirements.
A faculty member is a MS or PhD advisor for a student whose thesis or dissertation is considered basic, fundamental research and is not on restricted or controlled technology lists. Does this need to be submitted? No. Routine advising on non‑sensitive, fundamental research is considered Tier 1 academic activity and does not require submission.
Do faculty have to submit for every Zoom call with a foreign collaborator? No. Routine academic or research conversations do not require submission. This includes regular calls, emails, or virtual meetings that are part of ongoing scholarly collaboration, unless the engagement involves additional Tier 2 or Tier 3 criteria, such as formal government involvement, agreement discussions, or sensitive or dual-use subject matter. Presence of a designated country alone does not require submission.
A faculty or staff member wants to attend the Worlds Materials Society meeting to be held in Beijing. The conference is open to individuals interested in materials research who are willing to pay the registration fee. Does this need to be submitted? Attendance at open, public academic conferences is considered Tier 1 activity and is managed through normal campus travel or activity approval processes. Submission to SUNY System is not required solely because of the conference location, provided there are no planned meetings with foreign government representatives or non‑open, sensitive components.
Are conference presentations or invited talks included? Presenting at or attending open conferences, seminars, or invited talks is considered routine academic activity and does not require submission when the event is open and does not involve sensitive subject matter, restricted access, or formal government engagement. If a presentation includes a planned meeting with a foreign government representative or involves non‑open or sensitive elements, submission may be required.
A professor or staff member sits on the governing board of a university in the EU. As a board member, the travel to the annual on-site meeting is paid for by the university. Does this need to be submitted? If the institution is in a non‑designated country, this activity does not require submission, though it might need to be disclosed through any applicable New York State conflict‑of‑interest and/or ethics processes. If the institution is in a designated country, submission is required so the engagement can be logged and reviewed.
Can I apply for EU or DAAD funding opportunities without prior approval? Yes. These funding programs are open and competitive, so no submission is required.
What if we already have a SUNY-approved MOU with the foreign university? This guidance applies to both new and existing relationships. If activities connected to an existing MOU meet the criteria for submission, such as renewal or renegotiation discussions or other engagements that rise above routine academic activity, a submission should be made so the activity can be logged under the current framework.
How do we handle ongoing partnerships with multiple meetings throughout the year? If an ongoing partnership meets the criteria for submission under this guidance, campuses may submit one form that describes the purpose of the partnership, the types of meetings involved, and their general frequency. You do not need to submit a separate form for each routine meeting unless something meaningful changes.
What if we host recurring international delegations - do we resubmit each time? If the delegation meets the thresholds in the guidance, please submit one form that explains the nature of the visits, how often they occur, and the types of attendees and activities involved. You do not need to submit a new form for each individual visit unless something meaningful changes.
Do we have to submit for every student recruitment trip abroad? No. Routine student recruitment and admissions activities do not require submission. These trips fall within Tier 1 and can be managed entirely through campus processes.
Can we continue to use recruiting agencies or agents in China? Yes. Campuses may continue to use recruiting agencies or agents in China. Campuses should maintain a comprehensive record or registry of all such arrangements and review them through their standard contracting, compliance, and international activity processes, consistent with existing campus and SUNY requirements.
Are alumni events or donor meetings abroad covered? No. These events are hosted by the campus and do not involve foreign government representatives, so no submission is required unless a planned meeting with a foreign official is part of the agenda.
Do visiting scholar invitations trigger a submission requirement? Prior to submitting internal requests for appointments and J1 visas, visiting scholar invitations require submission only when they involve a designated country and a government affiliated institution or sensitive subject matter. Routine visiting scholars that do not meet these criteria do not require submission.
A faculty member is asked to serve as an instructor for the UN's IAEA Nuclear Management School to be held in Beirut. Does this need to be submitted? Yes. This involves a designated country and a topic area that may intersect with sensitive or dual-use technologies. Please submit a form so it can be reviewed.
A faculty member has a course in which s/he invites members of the diplomatic corps from various countries to give invited lectures to the class. Does each invitation need to be submitted? Submit one form that includes a short summary of the course/program, the list of intended guests with their names and titles if known, and a brief explanation of why each individual is being invited, e.g., their role. You do not need to submit a separate form for each lecture.
What if a faculty member meets a foreign official informally, like at a conference reception? Informal or unplanned encounters do not require advance submission.
Are student-run or club activities covered? Student activities are included only when the group is formally representing SUNY or the campus in a planned meeting with a foreign government representative. Otherwise, student-run or club activities do not fall under this process.
Submission & Review Process, Roles, and Data Handling
Does this process supplant the existing processes for submitting MOUs, Agreements, etc.? This process does not supersede existing processes within SUNY System Academic Affairs, Office of Global Affairs, or Office of General Counsel for program review, MOU, agreement, or contract review and approval. It operates alongside those processes and provides notification of discussions and meetings related to new agreements or renewal of agreements. It does not include submitting the agreements themselves.
Is this an approval or submission process? It is both, depending on the Tier. Campuses review and approve activities locally for all tiers before submission. Tier 1 activities are approved and managed entirely at the campus, with no submission required. Tier 2 activities require local approval and then submission for System‑level visibility and tracking and are not intended to require active review, so campuses may proceed unless contacted for clarification. Tier 3 activities also begin with campus review and then move into a structured risk‑review pathway at SUNY System, which may clear the activity, request additional information, recommend mitigations or conditions, or escalate the activity for further determination where unresolved risk remains.
Do Tier 2 submissions require SUNY System review or approval before we can proceed? No. Tier 2 submissions are intended to provide System-level visibility and tracking and are not intended to require active review. Campuses may proceed following local approval unless SUNY System contacts you for clarification or follow-up.
Who at the campus should be responsible for submitting the form - faculty, department chair, or the international office? Each campus may choose its own process for pre‑screening and submission. In general, it is most effective for faculty or staff to work through their campus and for a designated office or single point of contact to submit the form, with campus offices providing internal review as appropriate. This approach helps avoid duplication and supports consistent application of the guidance.
Can a Campus deny an activity locally without consulting System? Yes. Campuses may deny or return activities during their local pre-screening if they do not meet campus standards or cannot be supported under existing policies. Only activities that pass the local review proceed to SUNY System.
How do RF-funded projects differ from campus-funded projects? There is no difference for the purposes of this process. The submission requirements are based on the activity and its international context, not on the funding source.
If the RF is the contracting entity, does the campus still submit the form? Yes. The campus should submit the form so the activity is recorded and routed appropriately, even when the RF holds the contract.
What if the project involves both SUNY and RF participants? Please make one coordinated submission that identifies the roles of both SUNY and RF participants. The review team will route the information as needed to ensure all parties are included.
How far in advance do we need to submit? Please submit the form as early as possible. We recognize that campuses sometimes receive little notice, and we will work with you when time is short. The sooner you can submit, the easier it is for us to support the activity.
What happens if we miss the pre-submission window? Please submit the form after the meeting or event. It is important that the activity is still logged, even if it occurs before a submission could be made.
Can we submit after a meeting has already occurred if it was unplanned? Yes. Please submit the form as soon as you can so the activity is recorded and can be reviewed if needed.
How long does it typically take for a submission to be reviewed? Our goal is to provide notification within two business days, and often sooner. If additional information is needed, we will reach out promptly to keep the process moving.
How will we know if a submission is cleared or escalated? In most cases you can assume the activity is cleared unless we contact you. If a submission requires follow up, additional information, or escalation, SUNY System will notify you and your campus directly and quickly.
Does submitting an engagement mean it is likely to be denied or escalated? No. Tier 3 is a risk-review pathway, not a presumption of prohibition, and the majority of international activity continues to be managed through established campus processes. Risk is based on the activity and level of access, not country alone, and many Tier 3 submissions may be reviewed and cleared within SUNY when risks are understood and appropriately mitigated.
Can we proceed while the review is pending, or do we have to wait? If this is a Tier 1 activity, it is subject to campus process and procedure. If it is a Tier 2 or Tier 3, you may move forward while the review is pending unless SUNY System contacts you with a request to pause. If we need more information or see a concern that requires review first, we will let you know.
What if the meeting is cancelled or postponed - do we need to update the form? Yes. Please email IRISK@suny.edu with the change so the record can be updated. A brief note with the revised date or cancellation is sufficient.
Who decides whether something needs to be escalated? The SUNY International Risk Working Group reviews submissions flagged for potential concern and determines whether escalation to state partners is needed.
If something is escalated to DHSES, what happens next? SUNY will coordinate the review with DHSES and will follow up with either clearance, recommended conditions, or a determination not to proceed. Campuses will receive the outcome directly from SUNY.
Will campuses be notified when a case is escalated? Yes. SUNY will notify the campus if a case is escalated and will also share the final determination once the review is complete.
Can SUNY override a DHSES determination? No. When an activity is escalated, DHSES share risk information and a recommendation, and SUNY makes the determination and implements it, including any conditions, and communicates the outcome to the campus.
Is there a process for appealing or revising a decision? If you have new information or proposed mitigations, you can work with OGA to share those details. We will review the updated information and coordinate as appropriate with the relevant offices.
What information is visible to DHSES? Information submitted through the form is available to DHSES for State‑level awareness and reporting. DHSES engagement and review is limited to a subset of higher‑risk cases that are escalated or referred through SUNY System.
Who within SUNY System can see the tracker? Access will be limited to designated team members in the Office of General Counsel, the Chancellor's Office, the Provost's Office, and Risk Management. Access is role based and restricted to those responsible for policy implementation.
How long are records retained? Records will be retained according to SUNY's established records retention schedules. Campuses should follow their standard procedures for managing institutional records.
Is the data subject to FOIL requests? It may be. FOIL requests are evaluated on a case-by-case basis, and some sensitive information may qualify for exemptions. If you receive a FOIL inquiry or have concerns, please work with campus counsel to determine the appropriate response.
Will faculty names or project details be published externally? No. Information submitted through this process will not be publicly posted. It is used only for compliance, coordination, and required State reporting.
How often will SUNY share data or reports with DHSES? Information is shared in real time for any Tier 3 submission. SUNY also provides periodic aggregate reports to support awareness and compliance across other tiers.
Will SUNY submissions satisfy state requirements, or will DHSES still expect direct campus contact? SUNY's system serves as the single-entry point for campuses. You will not need to contact DHSES directly unless SUNY specifically advises you to do so.
Will DHSES contact campuses directly if they have questions? They may contact you directly. If that happens, please notify IRISK@suny.edu or your campus counsel so SUNY can help coordinate the response and ensure all parties have the same understanding.
Will the list of designated countries or restricted topics change over time? Yes. These lists may change as federal and State requirements evolve. SUNY will update the guidance when changes occur so campuses always have the most current information.
How will campuses be notified of those updates? SUNY will send update bulletins through the Office of Global Affairs, the Provost's Office, and the Office of General Counsel. Campuses should share those updates with faculty and staff who engage in international work.
Will SUNY review this process annually? Yes. SUNY will review the process at least once a year and make adjustments based on campus feedback, federal and State requirements, and trends in risk.
Will there be training sessions or office hours for campuses? Yes. The Office of Global Affairs will offer onboarding sessions, periodic refreshers, and office hours during the rollout so campuses can receive guidance and ask questions as the process gets underway.
Can we include this process in our existing research compliance training? Yes. Please integrate this guidance into your responsible conduct in research training, export control training, and general faculty onboarding materials where appropriate so that the expectations are clear from the start.
Who should we contact with case-specific questions? Please begin with your campus international office and campus counsel. They can answer many questions directly and will coordinate with SUNY System when additional guidance or review is needed. If needed, please email IRISK@suny.edu.
Are engagements initiated by DHSES or another state/federal agency exempt from this process? No. Please submit the engagement through the SUNY form so our records are complete and we can coordinate with the initiating agency. A short note stating that the meeting was initiated externally is helpful.
Are there any penalties for failing to submit a required engagement? Activities may be paused or denied if they have not been submitted as required. Repeated issues may lead to campus-level compliance follow up under existing SUNY policies. Our goal is to support compliance, so please reach out if you need help determining whether something qualifies.
What happens when another NYS agency (e.g., DOH, ESD, DEC) is also involved in a meeting? If SUNY personnel are participating in a meeting that meets the criteria for submission, please log it through the SUNY form. We will coordinate with the other agency to ensure the State has a complete view of the engagement.
If a campus is hosting a joint event with another state or federal entity, who takes the lead on submission? The host organization should submit the activity. If SUNY is co-hosting, please submit through the SUNY form so the engagement is recorded and routed correctly.
If a meeting with a foreign official or potential partner takes place at a U.S. Embassy abroad, does the same approval process apply? Yes. Location does not change the requirement. If you are planning to meet with a foreign government representative (domestically or overseas), please submit a form so the meeting is logged and reviewed as needed.
If recruiting activities abroad are sponsored by a U.S. Embassy or governmental entity such as Education USA, does the same submission process apply? Routine, open recruiting activities do not require submission. If your trip includes a planned meeting with a foreign government representative, please submit a form so that portion of the visit is captured.
If meetings with potential or current foreign partners and/or government officials are arranged by SUNY system, who will submit the meetings for review (e.g., in the context of a SUNY familiarization trip or system-wide initiative)? SUNY System will submit an umbrella entry. Campuses involved in the activity should still complete their local prescreening steps to ensure internal requirements are met.
Special Situations, Other Agencies, and Campus Implementation Issues
What about third-party or consortium meetings (e.g., with international partners but not directly hosted by SUNY)? Third-party or consortium meetings do not require submission unless a planned meeting with a foreign government representative is part of the agenda. If the gathering does not involve a government representative, no submission is needed.
Are events with the United Nations or World Bank included? Submit only if a planned meeting with a foreign government representative is part of your participation. If your involvement does not include such a meeting, no submission is required.
Do Fulbright or U.S. Department of State–sponsored meetings count? The U.S. government programming itself does not require submission. Submit only if your participation includes a planned meeting with a foreign government representative during the trip or project.
What if the meeting involves a private company that has partial government ownership? If the company is state owned, state controlled, or clearly linked to a political party, please treat it as government affiliated and submit a form. If you are unsure, submit the engagement and note your question so it can be reviewed and classified appropriately.
How do we handle hybrid events where some participants are foreign officials but others are not? If foreign officials are planned participants in your session or meeting, please submit a form. If they are simply attending an open event without a scheduled meeting or discussion with you, no submission is required.
What if a campus hosts an international conference and a government representative registers as an attendee? No submission is required if a government representative is only attending an open conference. If you schedule a meeting with them or plan a closed-door session as part of the event, please submit a form.
Are faculty consulting activities subject to the same review? If you are representing SUNY or relying on your SUNY role or resources in any way, the activity is subject to this process. Consulting activities should also be reviewed through your campus and State conflict of interest procedures so all required disclosures are appropriately captured.
How do we handle post-event reporting if something changes (e.g., new participants added)? The form's functionality is the same as an IT help desk ticket. If you previously submitted a form, you can go back into the form and update it with a post-event report modification. If you did not submit a form before the event and have something to report as a result of the event, please submit a new form. If you have questions, please email IRISK@suny.edu.
What should a campus do if a potential foreign partner refuses to share identifying information required for the form? The current form does not request personal identifying information. If future updates require additional details and the partner cannot provide them, please submit what you have and note the missing information. We will review the context and follow up as needed.
Do meetings with foreign officials in the U.S. (e.g., a meeting with a foreign ambassador to the U.S. or foreign embassy staff in Washington, D.C.) require the same approval process? Yes. Planned meetings with foreign ambassadors, embassy staff, or other national level diplomats require submission, even when the meeting takes place in the United States.
My campus does not have a travel policy or registry. What should we do? All campuses are required to comply with SUNY policies 8952 and 1550. Please review your campus processes to ensure compliance and identify how your existing workflows can support expanded travel review and registration. In addition, University Centers must maintain pre-approval processes under federal requirements in NSPM 33. Campuses should take steps to align their procedures with these expectations.
Can I co-publish with foreign colleagues? Yes. You may continue to publish with foreign colleagues. Open, peer reviewed publications such as IEEE journals, Nature, or Science do not require submission, even when the work involves colleagues in designated countries or in sensitive areas. If the publication or underlying work is non-public, restricted, or controlled, including research that is limited to specific participants, subject to contractual access restrictions, involves controlled datasets, or is not intended for broad academic dissemination, please submit a form so the activity can be reviewed.
