How is "Foreign National Visitor" defined? What qualifies as a "Visitor" for Export Control review purposes?
- Foreign National Visitors are individuals that meet all of the following:
- visiting VUMC campus on a short-term basis (typically less than 1 month),
- not requiring visa sponsorship by VUMC,
- not employed by VUMC.
- Foreign Visitors typically receive an official invitation from a VUMC host department that will allow them to be a guest on our campus for a specified amount of time and for a specific academic or research purpose.
- While at VUMC, Visitors should maintain an association with their host faculty member and department that will serve as the intellectual home for the Visitor.
The survey below is used to assist with the export compliance analysis. Submit your completed survey no later than 10 business days prior to the foreign national's visit.
**Preferably this step would be completed prior to extending an invitation, so as not to have to rescind the offer should the request not be approved.**
NOTE: When requesting citizenship/nationality/passport details from visitors, please note in your correspondence that the purpose of this requirement is necessary to comply with U.S. Export Control Regulations.
For record retention, keep all documentation related to the visit for five (5) years past the last date of recorded activity associated with the visitors.
When you are expecting a foreign visitor (colleagues, researchers, students, etc.) at your department, office, lab, etc., it is important to take into consideration what the purpose of their travel is, how their travel is being funded/supported, where they will be going while at VUMC, and (if research-related) what data and/or type of technology or information they will have access to during their visit.
Questions to consider (not exhaustive):
- Is the country the individual is from either a Tier 1 or 2 Country of Concern or a sanctioned country, etc.?
- Is the individual, entity, or organization they represent listed on any of the denied party lists (DPLs)?
- Is the research or any of the associated technology, lab equipment, etc. export-controlled?
- Is the research or any of the associated technology proprietary in nature?
- Is the individual an employee of a foreign owned company, a subsidiary, or US branch of a foreign company?
- Will the visitor be given access to laboratories or clinical areas during their visit?
Visitor Preparation Guidance
VUMC EC highly recommends that you, as the Host, should provide advanced notification to all relevant departments and individuals of the visitor(s) pending presence to ensure the workspace and any potentially export-controlled information/items, etc. are secured appropriately - prior to the visit. Certain situations may require a license from the federal government before a visitor may see a lab, research results, etc.
Contact VUMC EC for assistance with screening an entity or individual against the Denied Party Lists (DPLs). VUMC EC will provide a copy of the search records to you upon request. You should keep these results with the project file for five (5) years past the last date of activity on the project.
In preparation for a foreign national's visit to VUMC, contact the VUMC International Tax Office (ITO) for assistance. ITO will provide a questionnaire for the visitor to complete, if necessary. Please allow sufficient time for processing. To view the questionnaire, please contact ITO at firstname.lastname@example.org.