International Project Resources and Considerations

The resources and guidelines listed below are designed to assist you in navigating the complexities of international projects.

Please contact Global Services any time to discuss questions about the information below or to discuss considerations for your current or proposed project. You are welcome to reach out by email, or submit information about your activity in our International Project Review questionnaire. 

If you are undertaking international sponsored research, please coordinate with your Research Administration Services (RAS) team. 

Resources and Considerations for Global Work

To assist in your planning, please see additional global project planning considerations below:

Staffing: Are you employing (or planning to employ) local/foreign nationals? If so, please review our Staffing and Human Resources page to learn more about what options are available for your activity. As you plan for staffing your project, please keep in mind: 

• Staffing on a global project can take multiple forms (e.g., direct hire by Emory, direct hire by partner institution, independent contractor relationship, hire through a Professional Employer Organization, etc.).
• In most cases, Emory cannot legally hire non-US personnel for work outside of the US as employees. Extended assignments abroad for US-based Emory personnel must be considered on a case-by-case basis and could have substantial legal and tax implications for Emory and the employee.
• While an independent contractor arrangement can often seem like a simple staffing solution, contractor rules vary by country, and the feasibility of this approach must be evaluated on a case-by-case basis.
• Emory has a relationship with professional employer organization Mauve, which can also be explored as a means to engaging international staff for your project.
• Generally, having an in-country partner organization or subcontractor staff a project outside the US creates the least legal and administrative complexity for the PI and for Emory.

Operational needs outside the US: Global projects have a variety of operational needs – from procuring laptops for trainees to purchasing a project vehicle. As with hiring, operational needs met by in-country partners are much less complex than operational needs met directly by Emory University. If you plan for Emory to facilitate any of the following (or similar) activities, please contact Global Services, so we can discuss further and ensure you and your team are connected to all necessary oversight offices for such activities:

• Opening a bank account outside of the US 
• Leasing or purchasing residential space or office, laboratory, or other workspace outside the US (must coordinate with Emory’s Office of Real Estate Services)
• Purchasing vehicles or other heavy equipment for use outside the US
• Retaining security services (e.g., guards) outside the US

Insurance: It is important that you, and any employees or volunteers, be covered by the appropriate insurance.  

Money: Review our page on Banking and Purchasing for guidance on accessing funds and compliance purchasing overseas. 

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. 

Shipping or transporting materials: Your project may need to get equipment and materials to a foreign country/non-US location, and/or import equipment/materials/samples into the United States. In either case there are typically export and import processes and rules to consider. 

• For example, if an Emory project wants to ship or carry a number of laptops abroad (other than an individual bringing a laptop outside of the US for their own use), the Export Control office would need to confirm this export is allowable. Then, once the laptops arrive abroad, customs clearance would typically be required to facilitate their import.
• Further, if an Emory project needs to bring scientific samples from a study outside of the United States back to the US, a customs letter and/or customs clearing agency may be needed to ensure 1) the materials will be shipped properly, 2) the materials will be allowed to leave the country abroad, and 3) the materials will be allowed to enter the United States.
• The implications of handling the export and import of goods incorrectly can be serious and result in items being confiscated by government officials.
• Global Services is pleased to assist projects with the complexities of sending materials out of the US and bringing materials back into the US. You can learn more about resources and considerations shipping and transporting materials on the Global Services Import and Export page.

Travel considerations: Review resources from the Global Safety and Security team as well as International SOS. If you will be traveling overseas, please review our international travel resources. If you are leading a group abroad, please consult the Group Travel Checklist. See all the Global Services travel resources here. 

EHSO 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. 

Global activities requiring additional oversight or approvals

If your project would involve any of the following, please contact Global Services to discuss further, as these activities and operations typically require additional university oversight and approvals:

• Clinical trial or clinical research study outside the US, including but not limited to, projects involving the use of drugs, devices, biologics in humans (including as an in vitro diagnostic for humans), or behavioral interventions
  • Why? International clinical trials often require additional insurance, oversight, and approvals, and we want to ensure you have appropriate support when planning for an international clinical trial.

• Opening/establishing an office or legal entity overseas
  • Why? Opening an office and even a bank account overseas on behalf of Emory University requires Board of Trustees approval, as well as significant oversight from the Office of General Counsel and other administrative stakeholders. Opening an office outside the US can also include considerable cost associated with the registration, in-country legal and administrative review, and support to run such an entity. See more here. 

• Conducting work in or with a comprehensively embargoed country (Cuba, Iran, North Korea, Syria, or the Crimea, Donetsk and Luhansk regions of Ukraine)
  • Why? Work in comprehensively embargoed counties is heavily restricted by the US government, penalties for engaging with comprehensively embargoed countries without the appropriate license or permissions are serious and severe.
  • While such work is not impossible to perform, a thorough review must be performed by Emory’s Export Control office to determine if the work would violate US law and / or if it would require a license from the US government or other permissions.
  • In this instance, “work” in or with the countries referenced is defined in the broadest possible terms and could include travel to the referenced countries/regions, a partnership with an organization in the referenced countries/regions, or any type of engagement with individuals in said countries/regions.

Legal, Research Compliance, and Ethics considerations

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.  

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, Donetsk and Luhansk regions 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, and Yemen. Please note, the United Arab Emirates was removed from this list in April 2021. Please contact the Office of General Counsel if you plan to enter into any agreements with the above countries.

Research Data Security

Emory's Research Security Office can advise on data security planning for your research while traveling. Recommendations include but are not limited to:

• Maintain a data management plan
• Avoid traveling with unnecessary data
• Securely destroy unneeded data
• De-identify data when possible
• Report hacked, lost, or stolen devices as soon as possible to Emory Security (security@emory.edu)

Review the full set of recommendations:

Research Security Data Recommendations

Contact the Research Security Office (researchsecurity@emory.edu) with any questions.