GW International George Washington University
Policies that pertain to GW's international activity

GW INTERNATIONAL TRAVEL APPROVAL POLICY

A global perspective is essential to GW’s academic mission, and the University has long supported international travel to conduct research, study cultures and languages, promote collaboration with peer institutions, represent the University, and for other academic, administrative, and sanctioned student activities. The purpose of this policy is to outline the approval process for University-supported or University-related international travel, and related requirements, thereby promoting such travel while mitigating associated risks.

Any student, faculty, or staff member proposing to undertake University-supported or University-related international travel must follow the appropriate approval, insurance, and travel security requirements set forth in this policy. GW's Office of International Programs provides checklists specific to various purposes for University-related international travel.

If you have any questions about complying with the International Travel Approval Policy or registering your travel with the U.S. Department of State, please e-mail the Office of International Programs at sipadmin@gwu.edu.

If you have any questions about registering for or the coverage provided by International SOS Emergency Insurance and/or Summit America International Medical Insurance, please e-mail the Office of Risk Management at risk@gwu.edu.

APPROVAL OF ACADEMIC AGREEMENTS POLICY

Any academic department, center, office, or other University entity that desires to enter into any written agreement with one or more entities or individuals outside the University (including those overseas) for academic purposes must first submit the agreement to the appropriate University official(s) for required review and approval. There are separate procedures for approval of academic agreements in the Medical Center, which can be obtained from the Office of the Provost and Vice President for Health Affairs.

The purpose of the policy is to inform faculty and staff of the required approval and signature process for entering into written academic agreements with outside entities on behalf of the University, and to prevent the imposition of legally binding duties and liabilities on the University as a result of unapproved agreements.

INTERNATIONAL TRAVEL INSURANCE POLICY

The University provides International Travel Insurance to University employees engaged in University business abroad, as well as to graduate and undergraduate students completing departmentally approved course work or research abroad. Prior to the start of a trip or assignment, employees and students must register their travel plans online.

The purpose of the policy is to provide employees and students engaged in University business or travel abroad with information regarding the University’s international insurance program and travel services.

TRAVEL, ENTERTAINMENT, AND BUSINESS EXPENSE REIMBURSEMENT POLICY

The university will incur or reimburse expenses that are reasonable and necessary, are for a University business purpose, and are properly documented, approved, and submitted. This policy applies to all expenses as described below regardless of the account to which budgeted or recorded, or the type of funding supporting such expenses.

The purpose of the policy is to provide broad guidelines for incurring and reimbursing expenses connected with University business in accordance with applicable regulations and sound business practices. This policy governs expenses incurred during University travel, as well as expenses incurred locally in connection with University business.

EXPORT CONTROL POLICY (LIMITING DISTRIBUTION AND SHARING OF INFORMATION, TECHNOLOGY, AND COMMODITIES BOTH INTERNATIONALLY AND DOMESTICALLY)

It is the policy of the University to comply with U.S. export control laws. Export control laws restrict certain types of information, technologies, and commodities that can be transmitted overseas to individuals, including U.S. citizens, or made available to foreign nationals on U.S. soil.

It is the responsibility of faculty and administrators to be aware of and comply with these laws and the University’s written instructions and procedures.

FOREIGN GIFTS AND CONTRACTS DISCLOSURE POLICY

Departments, offices, schools, or other units receiving gifts of any value from a foreign source promptly must report such gifts to the Office of the Vice President for Development in accordance with the Gift Processing Policy, and promptly must report all contract s of any dollar value with foreign sources to Financial Reporting in the Office of the Comptroller.

The Higher Education Act of 1965 (HEA) requires institutions that receive a gift from or enter into a contract with a foreign source, the value of which is $250,000 or more considered alone or in combination with all other gifts from or contracts with the foreign source within a calendar year, to file a disclosure report with the Department of Education. Failure to file a disclosure report could result in civil action and assessment of costs against the University by the federal government.

A BRIEF PRIMER ON DOING BUSINESS ABROAD: U.S. LAWS THAT AFFECT GW'S INTERNATIONAL ACTIVITIES

A handful of U.S. laws apply to the University’s foreign business activities and to those who plan or implement them, even though those activities may be educational in purpose.  Many of these laws carry monetary and/or criminal penalties, for individuals and for corporate entities, like GW.  The University has prepared this Primer to explain the laws and how and when they may apply to your international activities.  The checklist at the end of this Primer should help you ask the right questions as you engage in activities abroad for GW.

The U.S. laws that affect GW’s business overseas can be grouped as follows: economic sanctions and boycotts, export controls, antiterrorism, and corrupt practices.  To illustrate the reach of some of these laws – in certain circumstances it may be a criminal offense to host a foreign government official or even to talk to him.  This Primer will explain why.  Other laws could apply to GW’s international business activities, such as environmental, employment, trade, tax, and antitrust laws.  Laws of the host country and a few international treaties will also affect the University’s foreign business activity.

TAX ISSUES REGARDING PAYMENTS TO INDIVIDUALS WHO ARE NOT U.S. CITIZENS OR NOT U.S. LAWFUL PERMANENT RESIDENTS

 

It is the policy of the University that payments made by the University to individuals, including students, who are not citizens, legal permanent residents or refugees of the United States, be made in compliance with the Department of Homeland Security (DHS) (formerly, U.S. Immigration and Naturalization Service (INS)), Internal Revenue Service (IRS), and state tax guidelines.  University departments and employees must not make any financial commitments before the DHS and tax implications are understood and communicated.

The laws and regulations that govern payments to individuals who are not citizens or legal permanent residents of the U.S. (sometimes referred to as “green card” holders) differ significantly from those that apply to U.S. citizens and legal permanent residents.  The University is potentially liable for tax, penalties and interest for failure to comply with DHS and IRS requirements.

 

 

 

Last Updated: 10/5/2009 8:01:04 AM