Export Compliance Policies & Procedures

International Visitor Reviews: Export violations can occur by sharing information, technology, or software and/or providing access to controlled equipment, materials, or research to a foreign national in the U.S. at University facilities. To mitigate this risk and as part of the University Export Management and Compliance Program, all international visitors should be cleared by our office prior to arrival at University facilities.

For international visitors arriving under J-1 or H1-B Visa sponsorship by the University, the required export review will be initiated automatically through the internal iStart system. For all other incoming international visitors, a review should be obtained from the University Office of Export Compliance at least 10 days prior to the arrival of the international visitor(s).

To facilitate the completion of such a review, please use the available online International Visitor Export Review Request Form and indicate on the form the nature of the proposed visit. This form should be used to initiate the required export review for international visitors who will be physically present at any Penn State facility. This form may also be used for international visitors to non-Penn State, U.S. locations where the U.S. visit is directly supported by or at the invitation of Penn State. This form should be completed by the Penn State faculty or administrative host and not by the international visitor(s). Information about the international visitor should be collected by the Penn State faculty or staff member submitting this review request form.

New Visiting Scholar Process: Effective November 1, 2019, all international visitors who qualify as a Visiting Scholar as defined under University Policy AC01, including domestic and international Visiting Scholars, must be processed by the Office of the Vice Provost for Faculty Affairs. This new Visiting Scholar Policy governs the process for designating and approving Visiting Scholars at Penn State. Additional information about this new process can be found at Penn State Visiting Scholars. Questions about the new Visiting Scholar process should be directed to the Vice Provost for Faculty Affairs at vpfa@psu.edu.

International Travel Reviews: International travel presents significant export compliance concerns, including, but not limited to, issues related to formal involvement with restricted or denied parties and international shipment and/or hand-carry of controlled items, information or software to international destinations.

• For Penn State Travelers: Under University Policy AD89, all University Persons must request a pre-travel review of planned international travel activities undertaken for official University business purposes prior to departure. No export review is required for purely personal travel events or for travel by students for non-University business purposes.
  
  The required export review of any covered international travel will be handled by the trained Export Compliance Specialists and staff within the University Export Compliance Office, including any travel related to or funded under a Sponsored Research grant, contract, or any other award vehicle. This pre-travel export compliance review is not an approval process but serves as the means to help to identify and mitigate export compliance "red flags" (risks) prior to the commencement of international travel activities.
  
  To facilitate the completion of an export review of foreign travel for University business purposes, University Persons may submit a request for review to the University Export Compliance Office by enrollment of the international travel event in the Travel Safety Network (TSN) system as required under the University International Travel Requirements Policy. Export reviews for University Affiliated International Travel will only be completed within the TSN system, so enrollment of all travel is recommended at least 30 days prior to departure. For travel events that are not required to be registered in the TSN or when circumstances prevent registration in the TSN, please contact the University Export Compliance Office for the latest Export Review Request Form for international travel. General questions about export compliance reviews of international travel may be directed to the UECO.
  

• For Non-Penn State Travelers: For non-Penn State Persons traveling internationally at Penn State expense, an export review is still required due to potential liability that may be assessed to Penn State given our fiscal responsibility for the travel. Non-PSU travelers may enroll their international travel in the TSN by contacting the TSN Staff to request access credentials for the TSN site. Alternatively, Non-PSU traveler activities may be reviewed for export purposes by following current processes for submitting such travel manually to the University Export Compliance Office for review. To request a copy of the current forms or procedures, please contact the University Export Compliance Office.

NOTICE: For travel to any U.S. sanctioned/embargoed destinations (currently Cuba, Iran, North Korea, Sudan and Syria), travelers should contact the University Export Compliance Office via email as soon as the decision to travel is made. For travel to some destinations, such as Iran, a U.S. export license or other governmental approval may be required. Application for and receipt of such licenses may require 4-6 months of processing time.

International Shipment Reviews: The shipment of commodities (items, materials, and goods) to international destinations is the most obvious example of an "Export", as that term is used under U.S. Export Controls. Penn State has a legal obligation under U.S. export and sanctions laws to comply with all relevant laws and regulations governing the international shipment of commodities. Pursuant to University Guideline AD09, the international shipment by any University Person of certain high-risk commodities should be reviewed in advance by the University Office of Export Compliance to determine whether any regulatory requirements are applicable to the shipment. In addition to various export compliance issues that might arise as part of a shipment out of the U.S., the importation (entry into the U.S.) of certain commodities requires compliance with a number of equally complex regulations, including potential customs, transportation, and licensing requirements.

To facilitate compliance and support international shipments at Penn State, the University Office of Export Compliance has created an online submission process to request that an export specialist review any proposed international shipment. To request an export review of any proposed international shipment, please see procedures related to Online Export Review Request Submission Forms for more information and to access our International Shipment - Export/Import Review Request Form. When required, an export review request should be submitted online at least FIVE (5) days prior to the desired date of shipment, however additional advanced submission is highly recommended.

PLEASE NOTE: An export review is a required part of the internal process for arranging the shipment of any hazardous, dangerous, or infectious commodities to any international destination via the hazardous shipment procedures administered by the Office of Environmental Health and Safety.

More information and access to the International Shipment - Export/Import Review Request Forms.

Online Export Review Request Submission Forms:
In order to standardize and facilitate timely reviews of Foreign Transactions at Penn State, the University Office of Export Compliance has created a number of Online Export Review Request Submission Forms. These forms may be used to provide the trained staff in the University Office of Export Compliance with the necessary information to quickly assess the potential for export "red flags" in certain Foreign Transactions. University faculty and staff are encouraged to utilize the online forms to ensure that all necessary information is obtained at the time of submission. The use of the online forms will create efficiency in processing by reducing the need for additional conversations and/or information gathering by the compliance specialist reviewing the submission. Each online form includes basic instructions regarding the use of the form.

• International Shipment - Export/Import Review Request Forms:
  The following forms may be used to initiate an export review of the international shipment of items, materials, equipment, and/or information (collectively "commodities"), including commodities that may be hazardous, dangerous, or specifically controlled under any applicable export control laws (including the ITAR or the EAR). The international shipment of hazardous/dangerous or potentially export controlled materials requires an export review prior to shipment per University Policy AD89 and University Guideline ADG09. Faculty and staff are also encouraged to submit other international shipments for review when they know, have reason to believe that, or are uncertain whether the items to be shipped may be controlled under U.S. export laws.
  
  The University Export Compliance Office has developed a new comprehensive online review request form to facilitate the efficient and effective review of any International Shipments, including both exports (out of the U.S.) and imports (into the U.S.). This new online form is available here: International Shipment - Export/Import Review Request Form. The new advanced form uses internal logic to ask more relevant questions depending on the nature and scope of the international shipment involved. The University Export Compliance Office recommends the use of this advanced form to enable a more seamless and comprehensive review.
  
  
• Export Compliance Review Request Form - Non-PSU Persons and University Supported International Travel:
  This form may be used to initiate an export review of international travel by non-PSU persons when such travel is to be reimbursed or purchased directly, in whole or in part, by the University. This form may not be used for University Persons (Penn State faculty, staff, or students) who are required by the University International Travel Requirements Policy to enroll their travel in the Travel Safety Network (TSN). Non-PSU Persons may contact the TSN Staff to enable access to the TSN system and, should they enroll their University-supported travel in the TSN, this form would not be required (as the foreign travel review will be completed in the TSN system). For the purposes of this form, international travel is a trip to an international destination, not a trip from an international destination to the USA (and then back). As an example, faculty supporting travel by a collaborator using gift funds to cover expenses for the foreign collaborator to come to Penn State for meetings is not international travel (as the destination is domestic) but should be considered a short-term visit (see International Visitor Form below). However, the same use of funds to cover the expenses of a non-PSU person related to their travel to an international conference would be considered international travel which should be reviewed using this form

• Export Compliance Review Request Form - International Visitors:
  This form may be used to initiate an export review of international visitors to Penn State when such visitors do not require formal Visa sponsorship by the University. Examples of international visitors in this category would include short-term visiting scholars, collaborators, and speakers; visiting international scholars arriving under a B-visa status; and/or other international visitors not otherwise reviewed for export compliance purposes under another internal Penn State process. This form should not be used for any international visitors being processed through the University Office of Global Programs using the Global Programs iStart system.
  
  

NOTE: For multiple international visitors arriving for the same Penn State event, please feel free to submit all international visitors using a single online request form. For events involving more than approximately 10 visitors, please prepare a spreadsheet listing, at a minimum, the full names, institutions/companies, current country of residence, and citizenship of each visitor prior to completing the online request form. This document can be uploaded as an attachment to the online request form. For additional questions about large group visits, please contact the University Office of Export Compliance directly for additional guidance.