1
- You are invited to speak at an international meeting sponsored by a foreign entity that has offered to pay for your travel and lodging.
- You advise a PhD graduate student who attends an international university. This is an unpaid adjunct appointment.
- You advise a student in another country and you are invited to speak at that university.
- You’ve been approached by a foreign talent recruiting program.
- As a researcher you anticipate having access to the laboratory resources of a foreign university or government through the existence of a lab in a foreign country.
For any scenarios not listed that you believe may be important to add to this list, please send your suggestion to researchsecurity-l@mtu.edu.
2
It is Michigan Tech’s policy to deny interaction with entities or individuals who are members of the Seven Sons of National Defense Universities. As of June 2021, the Seven Sons of National Defense Universities are:
- Beihang University,
- Beijing Institute of Technology,
- Harbin Engineering University,
- Harbin Institute of Technology,
- Nanjing University of Science and Technology,
- Nanjing University of Aeronautics and Astronautics, and
- Northwestern Polytechnical University.
The U.S. Government describes the ‘Seven Sons of National Defense’ as a group of leading Chinese universities with deep roots in the military and defense industry. The universities are all subordinate to the Ministry of Industry and Information Technology, which oversees China’s defense industry through its subordinate agency, State Administration for Science, Technology and Industry for National Defense (SASTIND).
3
Start with talking to your chair/supervisor and reviewing your sponsor requirements. One thing we’ve learned as various cases have been litigated and federal sponsors have developed their terms, conditions, and processes to assess these situations is, as a researcher it is best to disclose, disclose, disclose! The best course of action tends to be fact specific and may require further communication with your sponsor(s).
You may also contact researchsecurity-l@mtu.edu to start the discussion.
4
Per the University Conflict of Interest and sponsor policies and procedures, disclose all international research collaboration and relationships to the University (starting with your chair/supervisor) and to any U.S. sponsor supporting your research accordingly. It’s recommended you disclose prior to the collaboration taking place. If the collaboration is already in progress, disclose to your chair/supervisor and U.S. sponsors to your collaboration immediately.
5
Hosting foreign visitors on campus is valuable and important to the University’s mission. In order to ensure compliance with relevant federal regulations and University policies, all invitations for foreign visitors to campus require prior approval by the Vice President for Research. Please visit: Foreign Visitor Approval Process for more information.
6
Protecting University access and data while on travel is very important. The best thing to do is consult with the Information Technology group well in advance of your travel to ensure you are properly set up with your equipment/software for safeguarding your access and data while traveling. Consider your destination and all potential risks. The Information Technology group may offer or require a sanitized “loaner” laptop or phone to avoid exposure of your access or data. Avoid carrying any sensitive, proprietary, or confidential data. Also, never use a USB drive or other portable media given to you while traveling.
7
Generally, approval is not required, provided that the conference is not located in a country/region that is comprehensively sanctioned by the Treasury Department’s Office of Foreign Assets Control (OFAC). Comprehensively sanctioned OFAC countries/regions are listed on their website: OFAC Sanctions Programs.
Regardless of the conference location, you should present work that is either already in the public domain (published in books, journal articles, newsletters; publicly available technology and software; information presented at conferences, meetings, and seminars open to the public; information included in published patents; websites freely accessible to the public) or you intend to put it in the public domain, and is not subject to a sponsor review or restriction.
8
Yes, working with non-US citizens, including students, may require additional review and guidance prior to the work taking place if the work could result in a “deemed export violation”. A deemed export is the release of export-controlled technology, information, data, or source code to a non-US person within the US.