SUNY I-RISK Quick Guide

SUNY I-RISK Quick Guide

SUNY IRISK is a risk-based approach to international engagement. Most international academic activity is routine and remains under campus oversight. A smaller subset of activities requires System level visibility or risk review.


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Is the activity routine academic work?

Routine academic work includes the normal activities that support teaching, research, and student engagement, such as admissions and student services, study abroad programs, routine faculty collaboration, open research intended for publication, and existing agreements that are not being renegotiated.

 

TIER 1
TIER 2
TIER 3

If yes:

Classify as Tier 1 and follow normal campus protocols for travel, research, or international activity. No submission to SUNY is required.

When Activity Is Not Routine:

If the activity goes beyond routine academic work, it may fall into Tier 2 or Tier 3, depending on the nature of the engagement.

Tier 2 - System Awareness (Not Review)

Tier 2 covers activities that exceed routine engagement and require System level visibility, but do not present unresolved risk. This typically includes early or substantive discussions about new or renewed international agreements, joint funding discussions with foreign public entities, or formal meetings with diplomats or senior international officials.

  • Your campus submits the activity using the SUNY International Engagement Form (or an approved alternate campus process)
  • Activities may proceed following campus approval unless SUNY System contacts you for clarification
  • Submissions are logged for visibility and pattern analysis; routine review does not occur

Tier 3 - Risk Review (Not Automatic Escalation)

Tier 3 applies when activities involve designated countries together with risk enhancing characteristics, or sensitive or dual use subject matter regardless of country. These characteristics may include government-linked entities, nonpublic research, restricted facilities or data, sensitive technologies, or closed-door engagements..

  • Campuses review and screen Tier 3 activities first
  • Activities are submitted through the SUNY International Engagement Form for risk review
  • Many Tier 3 activities may be cleared with appropriate safeguards
  • Escalation beyond SUNY occurs only if unresolved risk remains

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:

  • Core Artificial Intelligence and purpose built Machine Learning applications that involve non public models, restricted datasets, autonomous systems, surveillance capabilities, defense or intelligence use cases, or are otherwise subject to export control or contractual restrictions.
  • Quantum Science and Computing
  • Semiconductors and Advanced Manufacturing
  • Aerospace, Aeronautical, or Defense Technologies
  • Biotechnology, Bioengineering, or Public Health Surveillance
  • Human-centered Computing/ Brain Intelligent Systems
  • Critical Infrastructure Systems, Cybersecurity, or Data Analytics
  • Nuclear, Chemical, or Energy Systems
Who does what in this process?
  • Campuses provide initial screening and local oversight.
  • SUNY System reviews Tier 2 and qualified Tier 3 activities.
  • State partners are engaged only for a limited subset of higher risk cases, as appropriate.

Bottom line

  • Risk is based on the activity and level of access, not country alone.
  • Tier 3 ≠ automatic “no.”
  • Most international academic work stays local.

Questions or unsure where something fits? Contact your campus international office or email IRISK@suny.edu