As of April 17, 2017

• Annual Certifications are due annually by May 1st
• For new Investigators an initial Annual Certification should be submitted prior to the submission of any proposals

When Is It Required to Report a Change in External Interests?

• Within thirty (30) days of discovering or acquiring a new FI or Obligation.
• At the time of establishing a faculty owned company.
• At the request of the DIO, where new FIs have come to the attention of the DIO.
• For PHS/NIH funded investigators, applicable travel must be disclosed within thirty (30) days of said travel. Alternatively, travel that is anticipated can be disclosed anytime in advance and would satisfy the thirty (30) day requirement.

A Significant Financial Interest (SFI) is a Financial Interest (FI) that you (or your spouse or dependent children) hold that reasonably appears to be related to your institutional responsibilities.

Institutional Responsibilities are those duties you have and activities you do as part of your professional responsibilities at the University, including, e.g., research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.) 

“…reasonably appears to be related to your institutional responsibilities…” means that if either your identified interests below, or the entity in which you have those interests, relies upon the same expertise utilized to carry out your Institutional responsibilities, it is considered an SFI. So, let's say you on a speaker's bureau for a company and present on topics related to the expertise you need to do your job at SBU. That would be a related interest. What if you were a paid board trustee for a religious organization? No, not related if you are an endocrinologist at the University. Yes, related if you are a faculty member in Religious Studies. Now let's say you are a paid member on a company's board. In this situation, it's not what you do for the company (serve as a board member, which may not be something you do at the University), but what the company's business is that must be considered in determining relatedness.  

Standard Operating Procedures - Effective April 17, 2017

Disclosures and Certifications

The Office of Research Compliance staff directory outlines the various individuals and their respective positions/roles. 

A person who is NOT:

• Granted permanent U.S. residence, as demonstrated by the issuance of a permanent residence card, i.e., a "Green Card"
• Granted U.S. citizenship
• Granted status as a "protected person" under 8 U.S.C. 1324b(a)(3), e.g., political refugees, political asylum holders, etc.
• It also means any foreign corporation, business association, partnership, trust, society or any other entity or group that is not incorporated or organized to do business in the United States, as well as international organizations, foreign governments and any agency or subdivision of foreign governments (e.g., diplomatic missions)

The release of technology or software subject to the Export Administration Regulations to a foreign national in the U.S. (although this term in not expressly stated in the International Traffic in Arms Regulations the same principles apply).

Deemed exports can be conveyed through visual inspection, oral exchange, electronic/digital exchange, made available by practice/application (e.g. training).

When receiving third party proprietary information and before sharing the information with a foreign national (even a fellow SBU employee or student) a deemed export review should be completed.

The TMP license exception, applies to the Export Administration Regulations and not the International Traffic in Arms Regulations.  A laptop must be “clean” - may not contain any export controlled technical data - to be eligible for the TMP license exception. In addition, the following must be followed: 

• you MUST retain exclusive control of the equipment at all times
• you MUST not let the equipment be used by anyone in the foreign country
• you MUST not intend to keep these items in these countries for longer than one year
• you MUST verify that no government licenses are required

Go to International Travel for additional consideration for traveling.

Before Shipping Checklist for Export Compliance

Is the item or technical information controlled under the export control regulations?

• Yes and it is controlled under the International Traffic in Arms Regulations (ITAR) – STOP - an export license is required
• Yes and it is controlled under the Export Administration Regulations (EAR) – STOP – an export license or a license exception may be required
• It is EAR99 - STOP - EAR99 items cannot be shipped to most restricted parties or to embargoed countries

Are you sending the item to an embargoed or sanctioned country?

Does the person or entity that you are sending the item to appear on any restricted parties lists?

Is it a legitimate end purpose?

International travel considerations include: country you are going to (is it a sanctioned/embargoed country), person/business/university you are visiting (are they a restricted entity), what you are taking (is a license needed or is there a license exception), and what you will be doing there (do you need a license).

Example - standard laptops qualify for license exception TMP. Although no license is required, there are requirements to be in compliance with the license exception: you MUST retain exclusive control of the equipment at all times, you MUST not let the equipment be used by anyone in the foreign country, you MUST not intend to keep these items in these countries for longer than one year, you MUST verify that no government licenses are required.

Example - even if you are conducting fundamental research, a license may still be required to bring field equipment. This is especially true for any military controlled items.

Example - travel to Cuba has recently opened up but travel is not completely open and not all activities are permitted.