Compliance Framework for Statewide Policy on Meetings with Foreign Government Representatives

New York Statewide Policy on Meetings with Foreign Government Representatives

Policy issued September 2, 2025

The State University of New York (“SUNY”) and the University at Buffalo (“UB”) are bound by the Statewide Policy on Meetings with Foreign Government Representatives (“policy”) issued September 2, 2025. UB has been directed by SUNY Office of General Counsel and the New York State Governor’s Office to disclose for review and approval:

  • Meetings with foreign government representatives on matters not related to routine functions in the normal course of university business.
  • All meetings or engagements—routine or not—involving foreign government officials or political representatives from countries designated by federal regulation as a “foreign country of concern,” which currently includes China, Iran, North Korea, and Russia.

To balance SUNY’s and UB’s missions with the policy’s objectives, SUNY and UB adopted the following framework for compliance and implementation, with non-exhaustive examples:

EXCLUDED: ROUTINE/ORDINARY COURSE OF BUSINESS MATTERS

The following activities should be treated as routine functions in the normal course of SUNY’s/UB’s business and therefore excluded from review:

  1. Processing international student admissions and enrollment, including routine communications with international applicants and their families.
  2. Administering and managing study abroad and student exchange programs, including processing student exchange/study abroad paperwork.
  3. Day-to-day correspondence by SUNY/UB faculty, researchers, and staff with foreign faculty and researchers on projects once they have been approved.
  4. Routine campus-based student services for international and/or study abroad students (housing, health, visa support).
  5. Implementation of previously approved education agreements, without material renegotiation or foreign government involvement.
  6. Basic science research engagements, particularly with foreign private universities.
  7. Academic collaborations at the faculty level.

INCLUDED: POLICY-LEVEL ENGAGEMENTS

I. For Foreign Countries of Concern (currently China, Iran, North Korea, or Russia):

  • Any meetings or engagements—routine or not—involving foreign government officials or political representatives from countries designated by federal regulation as a “foreign country of concern.” As of September 22, 2025, those countries are China, Iran, North Korea, or Russia.[i]

[i] “Foreign country of concern” is defined in 15 C.F.R. § 231.102 to include: (a) any “covered nation” under 10 U.S.C. § 4872(d) (currently China, Iran, North Korea, and Russia); and (b) any additional country the Secretary of Commerce designates, in consultation with the Secretaries of Defense and State and the Director of National Intelligence.

II. For Other Foreign Countries:

  • Formal negotiation of new agreements with foreign public universities or those with known foreign government connections.
  • High-level meetings with known foreign government officials or political representatives. Please err on the side of reporting.
  • In-person delegation visits to/from UB/SUNY institutions involving non-routine government-affiliated organizations. For this purpose, foreign public universities should be considered government-affiliated organizations, but the visit/event may fall into another reporting exclusion.
  • Research collaborations with foreign government involvement or sensitive technology implications (e.g., cybersecurity, defense-adjacent fields, critical technologies).
  • Non-routine meetings with representatives of foreign ministries of education, embassies, or consulates.
  • Joint funding discussions with foreign government agencies.
  • In-person delegations from Non-Government Organizations (NGOs) or foundations with known government/political ties.

UB’S REVIEW PROCESS

UB has created an internal system for reviewing requests for meetings with foreign government representatives. The first step of the process is to complete this form. You are required to submit the form at least 21 days in advance of your proposed meeting. The request will be reviewed internally and forwarded to SUNY Office of General Counsel and the New York State Division of Homeland Security and Emergency Services (DHSES), if appropriate. Additional information may be requested by DHSES.

Complete Form

Responsible Unit: Office of the Vice Provost for International Education

Contact: John Wood, Senior Associate Vice Provost

Email: forgovmtg@buffalo.edu

Phone: (716) 645-4884