International Visitors and Non-Immigrant Employees

Under U.S. export control laws and regulations, releasing controlled technology or technical data to a foreign national, even by an employer, is deemed as an export to that person’s country or countries of nationality. A license may be required before such a release can take place.
Similarly, export control regulations may apply to and have an impact on activities conducted with or by an international visitor. Examples of when export control regulations may apply to a visitor include:

• When activities that the visitor will engage in include research that cannot be categorized as fundamental research.
• When the visitor will have access to export controlled information or technology or will have access to secure facilities.
• When the visitor is a national of a sanctioned or embargoed country.
• When the visitor and/or the institution they are affiliated with appears in any of the restricted/prohibited parties lists.

ORICS has developed export control review procedures, Export Control Compliance Review for International Visitors and Non-immigrant Employees, that detail review procedures for activities related to international visitors and non-immigrant workers. A Visiting Scholars and Non-Immigrant Employees form must be completed for all international visitors and non-immigrant employees prior to commencement of visit or employment.

Visiting Scholars and Non-Immigrant Employees forms will be submitted through IRBManager beginning February 14, 2022. Information on IRBManager for these forms can be found in the Investigator Guide. Additionally, a quick video that covers how to complete the form in IRBManager can be found here.