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INTERNATIONAL RESEARCH

“I am a citizen of the world.”–Demosthenes

 

Research efforts undertaken abroad often entail unusual and sometimes unexpected challenges not generally encountered with domestic projects.  For example, we may find ourselves dealing with visa requirements, value-added taxes, export controls or economic sanctions, issues of non-U.S. law, language barriers, cultural differences, or processes unique to local organizations.  You can find general resources and assistance with such matters in the Office of Sponsored Projects Administration (SPA) and Global Programs and Strategy (GPS) Alliance.

The University Global Operations initiative can provide further guidance, options and advice regarding the operational aspects of international research.  Global Operations brings together experts in the following areas through its advisory team: 

  • tax,
  • banking and cash management,
  • purchasing,
  • legal,
  • human resources, and
  • compliance, among other issues.

Through Global Operations, SPA and GPS Alliance Work with units across the University to ensure comprehensive and timely responses to international operations questions.

 

KEY POINTS OF CONTACT


If you have any questions about international research, travel, or operations, please don’t hesitate to contact the following personnel.

For help with export controls, economic sanctions, and general international research issues:

Patrick Briscoe

Export Controls and International Projects Officer

Sponsored Projects Administration  

bris0022@umn.edu

612-625-3860

For help with various aspects of operating abroad, including local hiring, tax, visa, operating licenses, and other requirements:

Katie Van Geem

Associate Program Director, International Health, Safety and Compliance in GPS Alliance

vang0746@umn.edu

612-624-5075

For help with international insurance, travel, and related matters:

Kaoru Nunn

Program Associate, International Health, Safety and Compliance in GPS Alliance

nunnx016@umn.edu

612-626-8832

 

UNIVERSITY RESOURCES

 

EXTERNAL RESOURCES

 

ISSUES TO CONSIDER WHEN PLANNING RESEARCH ABROAD

 

Do I have to let the University know when I’m leaving the U.S. to work on a sponsored project?

How might the Fly America Act impact my travel?

Do I need prior University approval before traveling to certain dangerous locations?

Do I need special insurance coverage while traveling abroad?

Are there any other requirements for students traveling abroad?

Do I need a passport to travel abroad?

Will I need a visa? Can I just use a tourist visa from the host country?

What sort of liabilities might my presence in a foreign country create?

Should I keep U.S. embassy or consular officials apprised of our activities?

If I’m a U.S. citizen, am I subject to the laws of the non-U.S. country I visit?

If I get into any legal trouble abroad, the U.S. Government will bail me out, right?

What types of issues can arise when working with non-U.S. research collaborators?

What research compliance issues can arise in non-U.S. contexts?

What is the U.S. Foreign Corrupt Practices Act (FCPA)?

Will equipment or technology be exported from the U.S. or another country to the destination country?

 


 

ISSUES TO CONSIDER WHEN PLANNING RESEARCH ABROAD

Compared to projects conducted in the U.S., research efforts pursued in non-U.S. locations generally present elevated levels of risk—legal, financial, logistical, operational, and ethical.  Minimizing the University’s footprint abroad helps reduce many of these risks.  To the extent possible and consistent with project needs, we should issue subcontracts, subawards, or purchase orders to in-country organizations or personnel, rather than establish a direct University presence on the ground.  Keeping our personnel and assets out of the local jurisdiction can help us avoid many administrative and financial burdens, such as obtaining visas, registering with local authorities, paying certain taxes and fees, and becoming knowledgeable about (or subject to) non-U.S. laws and protocols.

Do I have to let the University know when I’m leaving the U.S. to work on a sponsored project?

Yes.  All University faculty and staff traveling outside the U.S. on University business are required to register their travel at the Faculty and Staff International Travel Registry.  The purpose of registration is primarily to gather basic information needed by University staff to contact and assist travelers if an emergency arises.  Registration information is kept confidential and is not published.  Registration also allows you to review valuable travel resources, including travel discounts, travel funding, and insurance information.  You may also choose to manage travel documents including passport copies and itinerary details.  You will have access to these materials before, during and after your travel.

How might the Fly America Act impact my travel?

The Fly America Act and associated regulations provide that federal funds may generally not be spent on flights operated by non-U.S. flag carriers.  In other words, unless an exception applies, sponsored funds that originate with a federal agency may be used to pay for only (a) flights on U.S. flag air carriers, or (b) code-shared flights (i.e., any flight on a non-U.S. carrier for which the ticket or itinerary shows a U.S. carrier flight number, such as “Delta 882, operated by KLM”).  For more details about these requirements, visit the University’s Fly America Act website or contact Patrick Briscoe (bris0022@umn.edu, 612-625-3860) in SPA.

Do I need prior University approval before traveling to certain dangerous locations?

It depends on the destination.  All University students, as well as faculty and staff traveling with students, traveling to countries under a U.S. Department of State’s travel warning must obtain approval from the University’s International Travel Risk Assessment and Advisory Committee (ITRAAC) prior to departure.  The ITRAAC approval process takes six to eight weeks after receipt of a completed application.

In addition, anyone planning to visit an embargoed country or region (Crimea, Cuba, Iran, North Korea, Sudan (North), or Syria) must first coordinate with the University Export Controls and International Projects Officer to ensure that no federal travel or trade restrictions are violated, and that any necessary licenses are obtained and followed.

Do I need special insurance coverage while traveling abroad?

In many cases, yes.  All students traveling abroad in connection with their University studies, as well as faculty and staff traveling with students, must obtain mandatory University-approved international travel, health, and security insurance through Cultural Insurance Services International (CISI).  The same requirement applies to all faculty and staff who are not covered by FrontierMEDEX through a U-Plan.  In addition, some colleges, departments, or units may have internal policies requiring all faculty and staff traveling internationally to obtain CISI coverage, so check with your college, department, or unit coordinator.  For more information about the necessary insurance, see the GPS Alliance’s International Insurance website.

Are there any other requirements for students traveling abroad?

Yes.  Students traveling abroad for University purposes must meet all requirements in the Student International Travel and Education Abroad: Health and Safety University policy, which include:

  • Registering travel officially with the University;
  • Signing a Student Release and Waiver detailing the academic, financial, behavioral, travel risk, and health-related responsibilities while abroad;
  • Obtaining University-approved international travel, health and security insurance;
  • Creating an emergency communications plan;
  • Completing the mandatory online health and safety orientation; and
  • Addressing any health and safety concerns prior to departure (e.g., check-ups, immunizations).

Students working through an education abroad office will complete the requirements through the application, confirmation and pre-departure process.  Students not working through an education abroad office will complete the requirements by first registering their travel at the Student International Travel Registry, which will facilitate completion of the remaining requirements.

Do I need a passport to travel abroad?

Yes.  Anyone traveling abroad will need a passport issued by the government of his or her citizenship.  For information on obtaining a U.S. passport in Minnesota, visit the U.S. Department of State’s website for the Minneapolis Passport Agency.  In addition, make sure that your passport is valid for at least six months after your planned returned date as this is required by many countries.

Will I need a visa? Can I just use a tourist visa from the host country?

It depends.  Entry into every country is governed by that country’s immigration laws, which may require a visa issued by the host government.  Whether and what kind of a visa is needed will depend on a variety of factors, including the planned visit’s length, purpose, destination, and the traveler’s country of citizenship.  Personnel must comply with the visa requirements of the countries they are entering, and tourist visas are generally appropriate only for tourism. 

The process of obtaining visas from non-U.S. governments is generally handled through their diplomatic or consular missions in the U.S.  The U.S. Department of State publishes basic information on visa requirements by country, and often provides links to the relevant embassy and consulate websites.  Go to the U.S. Department of State’s International Travel website, select your destination from the drop-down menu in the middle of the page, and find “Entry/Exit Requirements for U.S. Citizens.”

You and your College or Department have primary responsibility for obtaining any visa(s) needed in connection with research in a non-U.S. country, but you should not hesitate to contact the Export Controls and International Projects Officer in SPA with any questions. Additional resources are available on the GPS Alliance Travel Resources website under Travel Documentation.

What sort of liabilities might my presence in a foreign country create?

Activities abroad are subject to in-country laws.  Depending on the location, the length of your presence, and the details of your operations, the University may become subject to a variety of local legal requirements.  A project can trigger regulatory obligations involving taxation, business registration, workplace safety, and other areas.  Global Operations can help sort through the requirements as needed.

Should I keep U.S. embassy or consular officials apprised of our activities? 

It wouldn’t hurt, certainly with larger projects.  U.S. Government missions often have professional staff who are dedicated to certain social, educational, and scientific issues, and who may have insights into developing local relationships and establishing in-country operations.  All University travelers are strongly encouraged to register with the U.S. Department of State Smart Traveler Enrollment Program.

If I’m a U.S. citizen, am I subject to the laws of the non-U.S. country I visit?

Yes.  You are subject to all the civil and criminal laws of the jurisdiction in which you find yourself.  Adhering to universal rules of good behavior—don’t lie, steal, fight, kill, bribe, do drugs, or break a promise—will go a long way in avoiding potential legal penalties.  You should nonetheless be mindful that certain conduct that is perfectly lawful in the U.S. may cause problems in other jurisdictions.  Examples include criticizing local government authorities, drinking alcoholic beverages, photographing military buildings or personnel, or possessing violent, adult, or subversive literature.  It’s a good idea to do some cultural and legal research before your trip.

If I get into any legal trouble abroad, the U.S. Government will bail me out, right?

Don’t count on it.  If there’s a legal problem, you (and in some cases, the University) may be held liable pursuant to the host country’s civil or criminal laws, and the U.S. Government’s ability to assist will be limited.  Even if you find yourself imprisoned, the most you should expect from the nearest U.S. diplomatic mission is a personal visit and some advocacy to the authorities that you receive assistance of counsel, the benefits of due process, and similar basic protections.  The U.S. Government is not in a position to free U.S. citizens jailed in accordance with local law.

What types of issues can arise when working with non-U.S. research collaborators?

Subawards and subcontracts to collaborators abroad are generally administered by the same Grant Administrator in SPA who facilitated the prime, and who can help sort through term flowdowns, negotiations, and related issues.

Considerations unique to international subaward management can include—

  • Foreign research compliance and ethics requirements,
  • Prior federal sponsor approval for fixed price/rate subawards,
  • $150,000 cap on fixed price/rate subawards,
  • Costs of certain short-term visas may be chargable to federal sponsored projects,
  • Evaluation of exchange rates/wire transfers and banking information,
  • Invoice problems,
  • Language-translation issues and costs,
  • Indirect Costs (10% de minimis rate for federal subawards issued under the Uniform Guidance), and
  • Communication tools, time zones, and individuals/rates.

What research compliance issues can arise in non-U.S. contexts?

Sponsored research is generally subject to the compliance requirements of both the sponsor’s country and the country in which research occurs.  Thus, an NSF project involving field work in India must comply both with U.S. regulations and grant terms, as well as applicable Indian standards.  Compliance areas to assess will depend on the details of a given project, and may include—

  • Animal testing and welfare,
  • Human subject testing,
  • Financial conflict of interest,
  • Anti-corruption (especially the U.S. Foreign Corrupt Practices Act),
  • Environmental and natural resource protection,
  • Shipping, customs, hazardous materials, etc., and
  • Workplace safety, especially when dealing with biohazards.

What is the U.S. Foreign Corrupt Practices Act (FCPA)?

The FCPA is federal legislation that prohibits persons subject to U.S. law from corruptly paying, promising to pay, or authorizing the payment of money or anything of value to foreign officials or their family members for purposes of obtaining or retaining an unfair advantage.  In short, bribery is a federal crime under the FCPA, as well as a violation of the University’s Code of Conduct.

Three concepts in particular are worth exploring further.

First, prohibited items can take the form not just of cash payments, but also of extraordinary and unreasonable gifts, favors, rebates, tickets, entertainment, resources, contributions, loans—in other words, anything of value given for corrupt purposes.

Second, corrupt payments need not be made directly by University personnel to cause problems.  If one of our consultants or collaborators, for instance, were to promise foreign government officials that their children would be given favorable tuition treatment at the University in exchange for the issuance of a grant, the University might be held liable for an FCPA violation.

Third, the FCPA does allow for a variety of legitimate, bona fide presents and payments, including gifts of reasonable value and standard fees and taxes for non-discretionary government services (for instance--permit application fees, customs duties, local taxes, etc.).

Questions about FCPA compliance may be directed to Patrick Briscoe (bris0022@umn.edu, 612-625-3860) in SPA.  Persons wishing to file confidential reports of potential infractions may do so online (www.Ureport.ethicspoint.com) or by phone (1-866-294-8680) in accordance with the University's Policy on Reporting and Addressing Concerns of Misconduct.

 

Will equipment or technology be exported from the U.S. or another country to the destination country?

Moving items internationally can implicate a number of U.S. and foreign requirements that don’t apply to solely domestic activities.

              Exports—Moving items out of a country, in particular the U.S., may require prior government authorization, depending on what exactly is going abroad, where it’s going, what it’ll be used for, and other factors.  Items subject to control can include encryption software, satellite and military goods and technologies, cultural artifacts, biological agents, protected natural resources, and a variety of other commodities.

For details on export control requirements, contact Patrick Briscoe, the University’s Export Controls Officer, or visit the Export Controls site.  Getting U.S. Government export authorization can take anywhere from one to three months, so it’s best to address this issue sooner rather than later.  Even if export controls do not apply to a shipment, there may be reporting requirements with which Patrick or your carrier (FedEx, DHL, etc.) can help.

              Imports—Sending items into various countries can trigger their requirements for customs clearance, duty payments, and/or import permits (especially for biological or hazardous items).  The rules vary from country to country.  In many cases, coordinating shipments with local collaborators will mitigate the risks of delay and liability.

 

 
 
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