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Research Policy and Compliance  /  Export Compliance  /  Foreign Person Reviews

Foreign Person Reviews

What is the Foreign Person Questionnaire (FPQ)?

The Caltech Office of Export Compliance (OEC) uses a form called the Foreign Person Questionnaire (FPQ) to determine whether a Foreign Person working on a controlled project will need an export license.

INSTRUCTIONS:
Please follow the guidelines in the matrix below when evaluating the need to submit an FPQ to the Office of Export Compliance. You should reference the Award Summary for the PTA the beneficiary is being added to or accessing (that is, even when they are not being paid by the PTA) to determine if an FPQ needs to be submitted for review. If you do not have access to the Award Summary, please contact the grant manager or export compliance.

Important: the Office of Export Compliance reviews only a subset of all campus awards. If you feel the need to have our office review an FP addition that does not fall under the matrix criteria, in particular with regards to federal awards that involve sensitive technologies, you are welcome to submit an FPQ for export-control review out of an abundance of caution.

FPQ Mini Chart

[1]An "Export Controlled project" can be identified if: a) it has a Technology Control Plan (TCP), or b) the award summary contains OGM term #5 with the condition that "the PI must notify the Caltech Export Compliance Office in advance if any Foreign Persons will participate in this project." Export controlled projects have a "red flag", such as the need to receive 3rd party-JPL export controlled items (hardware, software or technical data), the project has problematic contractual clauses or involves high regulatory controls (ITAR or high-EAR – under the Department of State or Bureau of Industry and Security).

[2] Sanctioned or embargoed countries: Belarus, Cuba, Iran, North Korea, Russia, Sudan, Syria

Restricted Party Screening Instructions and Guidance

Please contact us to get access to the restricted party screening software tool (Visual Compliance https://www.visualcompliance.com/) . Guidance and instructions to using the software can be found here. (CIT internal document, requires login to download). You are welcome to schedule a brief tutorial session with Visual Compliance or our office.

FAQ:

No, generally, only EAS, PMA, some space-related GPS activities, foreign talent related programs, access to 3rd party-JPL export controlled items (hardware, software, technical data), or restricted party engagements will require review.

Although Restricted Party Screening (RPS) is a part of an export review, the tool is available to all of campus. You can request access to Visual Compliance by contacting us. The advantage of running your own RPS is that it is simple and will allow you to navigate the FPQ flowchart autonomously.

Fundamental research may still require an FPQ. Check the award summary for a Technology Control Plan or for OGM term #5 with the condition that "the PI must notify the Caltech Export Compliance Office in advance if any Foreign Persons will participate in this project."

If your RPS result is a CDU "Australia Unitracker Chinese Defense Universities List", you do not need to submit an FPQ. The CDU is an Australian advisory list which does not prohibit engaging with the entity. However, it may be prudent for you to make the faculty or researcher aware of this affiliation. Please contact the Office of Export Compliance for any questions or visit [https://unitracker.aspi.org.au/] for more information on the initiative.

HPC access only requires an FPQ if it is being accessed by a restricted party, or if the HPC is being accessed remotely from Belarus, Cuba, Iran, North Korea, Russia, Sudan, Syria.

NASA Restrictions on Funding Activities with the People's Republic of China (PRC), for additional information please see:

Contacts

Export Compliance contacts

Forms