Foreign Person Questionnaire (FPQ)
The Caltech Office of Export Compliance (OEC) uses the Foreign Person Questionnaire (FPQ) to determine whether a Foreign Person working on a controlled project will need an export license or other requirements.
When is a Foreign Person Questionnaire Required?
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 Export review is necessary. If you do not have access to the Award Summary, please contact the grant manager or export compliance. Generally, 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.
Our office only requires reviews of foreign persons per the conditions outlined in this chart below. Although Restricted Party Screening (RPS) is a part of our review, this function is not exclusive to our office since the tool is available to all of campus. The responsibility of running RPS on the beneficiary and their affiliated parties prior to onboarding falls on the requestor. If the beneficiary is conducting research that falls outside the "Fundamental Research Exemption (FRE)", please contact our office for additional guidance.
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.
 A US person is a US citizen, dual-citizen, permanent resident (green card holder), or asylee.
 If your RPS result is a CDU "Australia Unitracker Chinese Defense Universities List", you do not need to submit an FPQ, as this is an 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.
 See: https://hr.caltech.edu/documents/2650/caltech_institute_policy-compliance_with_export_laws_and_regulations.pdf
 Examples of non-researchers include administrative staff, non-research student volunteers, library access requests, or guest speakers with no access to export-controlled information.
 An "export controlled project" can be identified as follows: a) it has a Technology Control Plan (TCP), or b) the Export Compliance OGM term number 5 is in your Award Summary - "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) with high regulatory controlled items: ITAR (military or space application controls) or high-EAR (dual-use controls) under the jurisdiction of the Department of State or Bureau of Industry and Security, the project has problematic contractual clauses, or involves parties of concern.
 Sanctioned or embargoed countries: Belarus, Cuba, Iran, North Korea, Russia, Sudan, Syria
 No remote access to export-controlled information allowed without review.
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.
NASA Restrictions on Funding Activities with the People's Republic of China (PRC), for additional information please see: