International Research Guidelines and Ethics


The following guidelines can help with procedural and ethical issues that commonly arise when conducting business, research, or programs overseas. 

Agreements

An international organization or government may request a Memorandum of Understanding (MOU) or other agreement with Emory when doing business together. Please review our Institutional Partnerships page to learn about the different kinds of agreements, agreement guidelines, and see a list of Emory’s international relationships. Please contact Tye Tavaras in the Office of Global Strategy and Initiatives with any questions about your agreement or the process.   

Project Oversight

Ensure your program or project has proper oversight considerations in place. These include:

  • Clear reporting lines for on-site operational managers and financial arrangements to a principal investigator (PI) or administrator at Emory
  • A designated financial manager at Emory to ensure appropriate documentation of expenses for reporting purposes, oversee compliance with university financial policies, and guard against fraud
  • Oversight from one lead financial manager when multiple departments are involved to help avoid gaps or confusion in responsibilities
  • Clarity for faculty, staff, and students working abroad on how to report problems with the project. Be sure overseas staff employed directly by Emory are aware of the following resources:
    • Emory Trust Line, for reporting potential ethical, legal, or business conduct violations or concerns in a confidential manner.
    • Faculty Staff Assistance Program (for employees only), which enhances employees’ emotional and physical health, performance, and wellbeing.
    • HR representatives by department, for locating your HR representative based on the school or division that sponsors an overseas program.

Research ethics and IP

Assess the ethics and intellectual property (IP) needs of your research.

Emory’s Institutional Review Board oversees research involving human subjects. Please coordinate research projects with the Emory IRB to remain compliant with US regulations. Keep in mind such research includes simply accepting data from partners in country.

Further, many countries maintain their own system for reviewing and approving research conducted within their borders that involve human subjects. IRB can help determine what permissions are required (see here and here – section 17). If you will need permits or assistance from in-country counsel to facilitate your research, the Office of General Counsel can connect you with resources.

If your project involves intellectual property to be protected, please contact the Office of General Counsel to coordinate the appropriate steps.

Legal Considerations

There are many U.S. laws that address doing business or conducting research in foreign countries or with foreign nationals. Some of these can carry heavy sanctions, which can even include jail time.

Be mindful of sanctions programs, export control restrictions and restricted party considerations. If your research will involve engagement with any of the following countries, or individuals in the following countries, notify the Export Control Office at exportcontrol@emory.edu, as additional screening, licenses, or advice regarding allowable activity or exports may be necessary: Cuba, Iran, North Korea, Syria and the Crimea Region of Ukraine. Export Control compliance and restricted party restricted are not limited to the OFAC programs listed above. Learn more about Export Control compliance for your activity on our Import and Export page.

Emory University is compelled to report on any activity involving countries that require cooperation with an international boycott, which include Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United Arab Emirates, and Yemen. Please contact the Office of General Counsel if you plan to enter into any agreements with the above countries.

Project planning considerations

Emory has developed an International Assessment Questionnaire to help think through the various aspects of international projects. Global Services receives completed questionnaires and will gladly review questionnaires for projects still in the planning phase - please just indicate that you are still confirming project details in the space provided in the questionnaire. If you have any questions about international project planning or would like to discuss your project, please reach out to Global Services any time. If you are undertaking international sponsored research, please coordinate with your Research Administration Services (RAS) team.  

Other international research project considerations include:

  • Insurance: It is important that you, and any employees or volunteers, be covered by the appropriate insurance.  
  • Staffing: Are you employing (or planning to employ) local/foreign nationals? If so, please review our Human Resources page for resources regarding university hiring and independent contractor resources. In addition, employing foreign nationals may require Emory to take certain steps, including registering or establishing a foreign entity in country, as well as contracting with a payroll service. Please contact the Office of the General Counsel if you are interested in employing employees to do work in other countries. 
  • Real estate: Are you renting or purchasing (or planning to rent or purchase) property? If so, please contact Emory’s Office of Real Estate Services.
  • Money: You may find that you will need to access funds while overseas. Our page on Banking and Purchasing has guidance and contacts for accessing funds as well as opening overseas bank accounts.
  • Currency fluctuations: Plan for local currency costs where applicable, especially for in-country expenditures. Review local currency fluctuations regularly and adjust budgetary projections accordingly to avoid surprises. For projects subject to CFR 200 Uniform Guidance (typically U.S. government-funded grants), this guidance on exchange rates from CFR 200.440 may be useful. 
  • Travel considerations: If you will be traveling overseas, please review the Travel Checklist. If you are leading a group abroad, please consult the Group Travel Checklist.
  • Contacts for project planning compliance: If you receive NIH funding or if Emory owns the facility in which research is being conducted, please contact the Office of Environmental Health and Safety to determine if there are any associated concerns or requirements for your research.