U.S. Laws Abroad
In addition to the laws of your host country, the following U.S. laws govern activities abroad. Ensuring you adhere to these laws protects you and the University from financial and criminal penalties.
You can start by:
- Reviewing the U.S. laws that apply overseas.
- Contacting us or one of the offices listed below if you have questions or concerns.
Bribes and Corruption
Corruption is a significant problem in many countries. Harvard faculty, staff, and students may face requests for bribes, “gifts,” informal "fees," or similar payments or may face temptation based on favorable treatment provided to other parties. Program leaders must make it clear that bribes are unacceptable.
Harvard employees and contractors working overseas need to be aware of the U.S. Foreign Corrupt Practices Act (FCPA) and understand how it's administered. The law applies to unlawful gifts and payments given to foreign governments or political officials to influence decisions. Depending on the country, government officials may include faculty and staff of universities. Harvard could be held liable for penalties for FCPA violations even if the payment is made by a local non-employee, as long as he or she acted on Harvard’s behalf.
For more information about the law and ways to avoid transgression, you can review Harvard Medical School’s FCPA guidance as well as the Office of General Counsel's (OGC) Rules to Keep in Mind When Conducting Business Overseas.
Buildings, offices, and residences (sometimes including hotel rooms) abroad that Harvard rents or controls and that are frequently used by students may trigger crime reporting to the U.S. federal government. The Clery Act requires colleges and universities to disclose information about campus crime, and this can extend to international locations. Our office tracks overseas incidents that are reported to Harvard Travel Assist and/or to our International Safety & Security team and reports them to the Harvard University Police Department (HUPD) as requested to include with Harvard's Clery Act statistics.
Whom you work with and where is just as important as how you work. Some countries, entities, and individuals are sanctioned by the U.S. government and may either be banned from conducting any type of work with U.S. organizations like Harvard or require a license to do so. These regulations are administered by the U.S. Department of Treasury Office of Foreign Assets Control (OFAC).
Before engaging in work with an international partner, the Office of the Vice Provost for Research (VPR) can assist you in determining if a country, entity, or individual is on a sanctioned list. VPR also provides guidance on specially designated national list screening and follow-up.
Export Control Regulations
U.S. export control regulations can extend to equipment, materials, or software brought overseas or shared with others in the U.S. These rules apply whether you ship or hand-carry the goods and information. In particular, scientific equipment and biological specimens are subject to a high level of scrutiny. For more information, review our exports and imports guidance.
The U.S. government prohibits U.S. organizations from participating in boycotts of other countries, most notably Israel. These regulations extend to international agreements that discriminate on the basis of race, religion, sex, national origin, or nationality. They also penalize organizations that provide any information about individuals to countries for boycott-related reasons. U.S. organizations that receive these requests are required to report them to the U.S. Department of Commerce Office of Antiboycott Compliance. You can also review antiboycott procedures outlined by the Harvard-Smithsonian Center for Astrophysics.