Visa Sponsorship Letter Procedure

Report
Visa Sponsorship Letter
Best Practice Procedure
Tracy Horridge
Export and Security Administrator
Thermo Scientific Portable Optical Analysis
Wilmington MA
Visa Sponsorship letters
• Needed to obtain a visa to visit the US by some Foreign nationals
• Based on country of citizenship
• 36 countries participate in the visa waiver program
• Letter writer assumes responsibility for the actions of the visitor while
the visitor is in the US
• The letter must contain accurate information, using false or misleading
information constitutes a felony
• What can go wrong?
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Corrective Action Taken
• Immediately implemented a procedure to be followed by all US
business units.
• Procedure was communicated directly to all Site Leaders
• The procedure requires that sponsor letters be approved by Site Leader
and a member of the Global Trade Compliance (GTC) team
• Addresses past deficiency, when sponsorship/invitation letters were
non-uniform and inadequate - written by a variety of personnel (sales
people, engineers, buyers, human resources, administrators)
• Export Coordinator involvement required
• Visitor must be screened against denied parties lists
• Must look at the controls of technology that the visitor may be exposed to
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When can we sponsor a visitor?
• Thermo Fisher only sponsors visas for valid business purposes
• Sponsorship for dates at Thermo facilities only.
• No leisure travel.
• No behavioral assurances or guarantees can be made
• Relatives of visitors should not be sponsored, letter is for visitor only
• Letter should be written per Thermo guidelines
• Visitors name, home address, date/place of birth, passport number,
place/date of issuance/expiry, employer
• Payment of travel expenses must be approved
• Care must be used not to violate the Foreign Corrupt Practices Act (FCPA)
or Thermo Fisher’s policies
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Sample Letter
…
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Compliance Concerns
• Understand our products and technology and what visitors will have
access to
• If there are controlled products or technology access may need to be
restricted or export license approved
• Be careful to prevent Deemed Exports
• If there is knowledge that visitor plans to visit other Thermo Fisher sites,
ensure that Export Coordinator at that site is notified and aware
• Red Flags
• Look for any indication that the visitor plans to stay in the US beyond visa
allowance
• Are they attempting to access restricted technology?
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Host Responsibilities
• Did the visitor show up/depart as scheduled
• If they do not show up, immediately advise the export coordinator for
reporting to GTC, Site Leader and Legal
• Assure that the visitor is accompanied at all times
• Visitors should not be allowed to roam the facility freely
• Submit a written report of the visit to the GTC Team
• Summary of meetings, training etc
• When did they arrive, depart
• Where did they go
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Web Tool Developed to Assist
• Website was designed to assist Thermo Fisher employees in the
creation of these letters
• Electronic approval and follow-up mechanism to help better manage
the process.
• Site Leader, business unit export coordinator, and GTC team will
receive notifications of the proposed visit
• No letters will be generated until approval by the appropriate parties
occurs.
• The drafter of the letter will receive emails after the visit requesting
information regarding the visit.
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Web Tool
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Web Tool
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Web Tool Information
• Series of checklists to assure compliance at all steps in the process
• Export Coordinator
• Site leader notification
• Main Checklist
• Visitor Information
• Travel Expense reimbursement
• Thermo Employee
• Follow up Checklist
• Did visitor arrive/depart as scheduled?
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Questions
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