U.S. Export Control Regulations

Foreign Scholar and Visitor Screening

Brown University screens certain foreign scholars and visitors to ensure compliance with federal regulations, and to provide guidance and education to hosting departments and visitors on applicable export control and sanctions regulations.  

Who needs to be screened?

Specifically, screening is required for the following groups:

  • Any visitor or visiting scholar from a comprehensively embargoed country or territory[1];
  • Any scholar sponsored by Brown University for an H-1B or O-1 visa;
  • Any visitor or visiting scholar coming to Brown University on a J visa.

Why are these groups screened?

The screening process is primarily used to determine if a foreign scholar or visitor is a restricted national or is affiliated with a restricted country, group, entity, or organization. If the former, Brown cannot host/sponsor the individual; if the latter, the Office of Research Integrity (ORI) will provide specific guidance to the hosting department on regulatory restrictions related to hosting and interacting with the foreign visitor who is affiliated with a restricted party. ORI will also provide guidance to the visitor to ensure that they do not accidentally violate any U.S. export control or sanctions laws while being here.

The screening process is also used to determine if government licenses and authorizations are needed prior to sharing technology and technical data with the visiting scholar. In the case of H-1B and O-1 visa applicants, this process is also used to make a deemed export attestation, which is a federal requirement.

How are the groups screened?

The screening is conducted by the Export Control Compliance Group within the Office of Research Integrity (ORI) at Brown, using a web-based screening tool called “Visual Compliance”.

In order to conduct the screening, hosting departments/faculty must provide certain information to the Office of Research Integrity/Export Control Compliance Team. The information is collected via the Foreign Scholar and Visitor Screening form. Please fill out the form and follow the instructions below.

Instructions for completing the Form: 

  • The Foreign Scholar and Visitor Screening Form must be completed and signed by the hosting PI/department
  • Completed and signed forms must be sent to the Export Control Officer in Brown's Office of Research Integrity for review and signature.  Send forms to [email protected].
  • The Export Control Officer will send a signed copy back to the hosting department, as well as to Brown's Office of International Student and Scholar Services (OISSS), if Brown provides visa sponsorship.
  • Screening and Certification forms for visa holders working at Brown affiliated hospitals can be sent directly to the hospital's Export Control Officer.

If you have questions about the Foreign Scholar and Visitor Screening Form or need assistance in determining how to answer some of the questions on the form, please contact Jacky SullivanJuliane Blyth or Torrey Truszkowski

Deemed Export Certification for H1B/O1 visa holders

Please note that the new Foreign Scholar and Visitor Screening form replaces the old H1-B/O-1 Deemed Export Certification form. The new form includes a deemed export certification, which must be completed by the sponsor, which is either the PI, if joining a lab, or the department chair.

What is a deemed export certification for H-1B and O-1 visa holders?

The U.S. Citizenship and Immigration Services (USCIS) requires the inclusion of a “Deemed Export Attestation” (Form 1-129) for all new and extension H-1B petitions and O-1 petitions. The Attestation is filled out by the visa petitioner (i.e., the PI and the University). The purpose of this form is to certify whether a license or other government authorization is required for the release of export-controlled technology or technical data to the foreign scholar while in the United States during his/her employment. Under the export control laws, technology and technical data provided to a foreign national within the US is considered a deemed export (that is, an export to the country of origin of the foreign national).

NEW/IMPORTANT - Additional Document Requests for STEM Visa Applicants 

International students who apply for visas to study in the STEM fields, including electrical engineering, computer science, biology, chemistry, chemical and nuclear physics, may be asked to submit additional documents to the visa processing consulate. Required additional documents may include a research and study plan and an advisor letter/questionnaire to be answered by the hosting PI at Brown. The questionnaire may include questions related to funding sources, access to export controlled technology and information, as well as a description of other projects that the applicant may have access to. 

Statements provided to the applicant should be complete and accurate. PIs who require assistance with the questionnaire and, in particular, with export control related questions, can contact ORI’s Export Control Team: [email protected].


[1] Currently: Cuba, North Korea, Iran, Syria, Sudan, the Crimea Region of the Ukraine