Well before traveling to any foreign countries on business or meeting with individuals from foreign countries, Buffalo State employees need to consider both Export Control requirements and Foreign Meeting disclosure requirements. 

Export Controls Compliance

The United States federal government has enacted laws that regulate the disclosure, shipment, use, transfer or transmissions of information, items, specific technology, software, and services to foreign persons and foreign countries for reasons of national security and foreign policy. These laws may also restrict transactions with prohibited countries, entities or persons.  These laws are applicable to U.S. citizens, and are relevant to the university community, especially in respect to travel, research, and dissemination of information conducted by individuals alone and/or in affiliation with the university. The laws applies to both physical and "deemed" exports of items, information, and technologies.

In recent years, penalties have been enhanced to impact not only individuals, but also institutions; thus, universities are required to implement export control programs to educate their employees and to facilitate the export control license application process when necessary and appropriate.

Fundamental Research

Many international research initiatives by our faculty will be covered by the fundamental research exception:

"No license is required to disclose to foreign persons information that is published and which is generally accessible or available and shared broadly in the research community." If collaborations and presentations do not meet the criteria of “fundamental research,”  faculty research may require an export controls license. Any restrictions like the following are considered "red flags" if they are applied to a research project or collaboration:

                • forbids the participation of foreign persons;
                • gives the sponsor a right to approve publications resulting from research;
                • restricts participation in research to certain individuals; or
                • restricts access to and disclosure of research results. 

University Personnel

All University faculty and staff are required to submit the Export Controls Foreign Travel Disclosure Form for Use by Academic Affairs Faculty and Staff a minimum of two weeks prior to international travel or commencement of projects where they will work with foreign persons, educational institutions, research meetings, or businesses. Routing instructions are provided on the form. If you are planning to travel to a country subject to U.S. sanctions, please plan ahead and notify us 1-2 months in advance to avoid problems or delays.

 Export Controls Form

Buffalo State Research  Foundation

RF Export Controls Form

SRF Export Controls Fact Sheet

Export Controls Compliance at Buffalo State, Sponsored Programs Office

New York State issued a Statewide Policy on Meetings with Foreign Government Representatives on September 2, 2025. In compliance with this policy, Buffalo State has been directed by SUNY to disclose for review and approval any meetings with foreign government representatives on matters not related to routine functions in the normal course of university business.  SUNY has set up a website with links to electronic forms.

The following activities are considered routine business and are excluded (Exempt/Tier 1)

  • Purely academic exchanges with international collaborators.
  • Processing international student admissions and enrollment, including routine communications with international applicants and their families.
  • Administering and managing study abroad and student exchange programs, including processing student exchange/study abroad paperwork.
  • Routine campus-based student services for international and/or study abroad students (housing, health, visa support).
  • Implementation of previously approved education agreements, without material renegotiation or foreign government involvement.

Tier 2 activities must be disclosed.  This includes:

  • Formal meetings with national‑level diplomats or provincial leaders
  • Initial or substantive discussions and communications related to new or revised agreements involving academic programming or research
  • Joint funding discussions with foreign public sources that are not broadly available to U.S. institutions.

Tier 3 activities must be disclosed and will be reviewed. These include:

  • elevated risk activities (Tier 2) engaging with sanctioned entities or countries of concern: Cuba, Iran, Russia, North Korea, China, Ukraine (Crimea, Luhansk, and Donetsk only), Venezuela, Belarus, Syria, Balkans, Burundi, Democratic Republic of the Congo, Lebanon, Libya, Somalia, South Sudan, Yemen and Zimbabwe.
  • discussion of topics of concern, regardless of country, including activities or engagements involving the following sensitive or dual use subject matter areas:

- Core Artificial Intelligence and purpose built Machine Learning applications that involve non‑public models, restricted datasets, autonomous systems, surveillance capabilities, defense or intelligence use cases, or are otherwise subject to export control or contractual restrictions.

- Quantum Science and Computing

- Semiconductors and Advanced Manufacturing 

- Aerospace, Aeronautical, or Defense Technologies 

- Biotechnology, Bioengineering, or Public Health Surveillance

- Human-centered Computing/ Brain Intelligent Systems

- Artificial Infrastructure Systems, Cybersecurity, or Data Analytics

- Nuclear, Chemical, or Energy Systems

For more details, visit the SUNY iRISK website. 

Disclosure Process

Complete and submit the appropriate electronic form.