1. The purpose of our procedure
This procedure explains how we identify, assess and manage Adelaide University foreign compliance activities and risks, and how we meet our obligations under Australian law. Please read this procedure in conjunction with the Foreign Compliance Policy.
This procedure authorises the Deputy Vice Chancellor – Research and Innovation and the Deputy Vice Chancellor – International and External Engagement to maintain the Foreign Arrangement Assessment Protocol(s) and associated foreign compliance protocol(s) for their respective portfolios.
This procedure authorises the Chief Security Officer to maintain the Foreign Compliance Review (FCR) process and supporting tools.
2. Who our procedure applies to
2.1 Inclusions
This procedure applies to:
- our staff
- our students (including prospective students)
- our titleholders
- contractors, consultants and visiting academics
- any person acting on behalf of or in association with Adelaide University in a foreign engagement context.
2.2 Exclusions
This procedure does not apply to:
- wholly domestic activities with no foreign entity, partner, country or citizen involved
- preapproved legacy arrangements that are unchanged since their last review, unless the Deputy Vice Chancellor – International and External Engagement directs that they be reassessed due to changes in legislation, government policy, or the University’s foreign compliance framework
- activities governed end to end by a separate specialist process (for example, Procurement) where this procedure would duplicate mandatory steps
- routine international activities (for example, attendance at international conferences) that do not involve foreign governance rights, technology transfer, data sharing, sanctions exposure, or significant foreign funding
- routine international student-facing activities (including general supervision or coursework)
- activities screened out as low risk during FCR triage (e.g., through the FCR form logic).
3. Our foreign compliance review procedure
Foreign compliance assessments reflect our legislative obligations and governance requirements, supported by a risk-based and proportionate review process. Where multiple pathways apply, complete all relevant checks before committing to any activity. Staff must follow this procedure together with the Adelaide University Foreign Compliance intranet guidance.
In addition to the FCR process, this procedure sets out how we manage foreign affiliations and key legislative compliance checks.
3.1 Identifying foreign compliance activities
An FCR must be completed once Adelaide University and a foreign party agree to proceed with an activity or engagement, such as a collaboration, seminar (virtual or in person), visit, joint program, grant application or other foreign arrangement. The FCR must be completed before Adelaide University commits to, or publicly announces, the activity.
In this procedure, research or research-related activities include activities that are proposed to be led by, support, enable or arise from Adelaide University’s research function. Without limitation, this includes activities that may involve research projects, research funding, research collaborations, research data or materials, research personnel, research training, research translation and commercialisation, research engagement, research infrastructure, or the dissemination of research outcomes.
Examples of formal foreign arrangements include:
- Research, consultancy, contract research, grant, joint venture, membership, alliance, centre, or affiliation that involves a foreign entity or funding source.
- Written or unwritten arrangement with a foreign government or other foreign organisation.
- Staff arrangements with, or under the direction of, foreign entities and/or individuals.
- Engagement of overseas‑based visitors, scholars or delegations.
- Offshore teaching, transnational education or joint programs, including teaching delivered in-country or via virtual or online means, with involvement of foreign institutions.
- Procurement of goods or services from foreign entities where national-security, export-control, sanctions or other risk factors are present (consistent with the FCR form screening).
- Activities involving sharing technology, software or data with foreign persons.
- Graduate research students or research staff with foreign sponsorships or foreign institutional affiliations, and any co-supervision or co-enrolment with foreign entities.
If any condition in this section applies, complete an FCR form (see section 3.2) before negotiating, committing or announcing the activity.
3.2 Completing and reviewing an FCR form
The FCR form collects key activity details, screens for legislative triggers (screening, Foreign Influence Transparency Scheme (FITS), Sanctions, Export Controls), and records approval outcomes.
3.2.1 How to access the FCR platform
- Submit a new FCR form via the Foreign Compliance intranet page.
3.2.2 Required information and documents include:
- descriptions of the activity, parties, locations and dates
- relevant drafts or agreements, memoranda of understanding (MoUs), invitations or statements of work (where available)
- funding source details and any third-party beneficiaries
- research scope, technologies and data to be shared
- export control classification where known and applicable
- known foreign affiliations or interests of participants including any gifts, benefits or travel funding
- due diligence results (for example, corporate registry extracts, website screenshots)
- any previous approvals, exemptions or legacy arrangement IDs.
3.2.3 Assessment
- FCR submissions are reviewed through Adelaide University’s foreign compliance assessment process, which may include internal consultation with relevant specialist units
- For the following activities, the Chief Security Officer will prepare a system-enabled and recorded recommendation for the Deputy Vice Chancellor – International and External Engagement before any determination is communicated to the applicant:
- any proposed agreement, variation or renewal with a foreign entity (including MoUs)
- any proposed multi-party agreement involving a foreign entity
- any proposal to invite an overseas-based individual or entity to Adelaide University (subject to any documented exceptions)
- any proposed delivery of seminars, workshops or similar academic events by overseas-based individuals or entities, whether delivered in person or via virtual or online means.
- Where the recommendation is to not endorse an activity, the Chief Security Officer will provide the Deputy Vice Chancellor – International and External Engagement with the rationale and may discuss the recommendation before a final decision is made by the Deputy Vice Chancellor –International and External Engagement.
- Where the decision of the Deputy Vice Chancellor – International and External Engagement departs from the recommendation, the Deputy Vice Chancellor – Research and Innovation will be promptly informed of the decision.
- Where disagreement regarding the endorsement outcome arises following this notification, the matter is discussed between the Chief Security Officer, the Deputy Vice Chancellor – International and External Engagement, the Deputy Vice Chancellor – Research and Innovation and, where relevant, the Deputy Vice Chancellor – Corporate.
- If agreement is not reached, the matter is escalated through existing Adelaide University governance mechanisms in accordance with this procedure and the Delegations Policy.
- Where an activity is identified as constituting a Foreign Arrangements Scheme (FAS) arrangement, notification is undertaken by Research Services or Global Partnerships, as relevant.
- Standard FCRs are usually assessed within five business days of receiving a complete submission; complex matters may take longer.
3.2.4 Outcome
- An activity may only proceed once an FCR is approved (with or without conditions).
- For research and research-related Agreements, endorsement by the Deputy Vice Chancellor – Research and Innovation is required prior to approval by the Deputy Vice Chancellor – International and External Engagement.
- Final approval of an FCR is made by the Deputy Vice Chancellor – International and External Engagement.
- Once approved, outcome details are recorded in the FCR and communicated to the applicant through the Foreign Compliance system. If the applicant disagrees with an endorsement outcome, they may lodge an appeal (see section 3.5).
- Where an activity also constitutes a foreign arrangement under the Foreign Relations (State and Territory Arrangements) Act 2020, the FCR assessment forms part of the inputs used in the [Foreign Compliance Protocol(s)].
- A consolidated summary of FCR outcomes is prepared on a scheduled reporting cycle to support oversight.
3.3 Managing foreign affiliations and interests
3.3.1 Who must declare
- Staff, students (including prospective graduate research students) and titleholders engaged in activities in section 3.1., or who hold ongoing foreign affiliations or interests
- staff in roles designated as requiring ongoing foreign-affiliation disclosure.
3.3.2 What must be declared
Staff must declare:
- positions, appointments, visiting roles, consultancies or advisory posts with foreign entities
- membership of foreign talent programs; foreign stipends, gifts or in‑kind benefits
- equity or significant financial interests involving foreign entities
- immediate family connections that create an actual, potential or perceived conflict relevant to the activity.
3.3.3 How we review
- Foreign affiliation declarations are triaged through the foreign compliance assessment process typically within five business days of receipt, with referral to conflict-of-interest processes where required.
- Outcomes may include management plans, additional conditions, or exclusion from the activity.
- Where a declaration relates to a proposed or current activity of the kind described in section 3.1, the reviewer may request that an FCR be submitted or updated.
- Outcomes of foreign affiliation declarations are recorded in the foreign compliance system and provided to the Deputy Vice Chancellor – Research and Innovation for research-related matters, and to the Deputy Vice Chancellor – International and External Engagement for all other foreign engagements.
3.4 Legislative compliance checks
Legislative compliance checks are undertaken as part of Adelaide University’s foreign compliance assessment processes. Staff must not progress negotiations or commitments until they are advised that the relevant checks are complete.
Sanctions screening
- Sanctions screening must be conducted using the instructions and resources on the Foreign Compliance intranet.
- All individuals and entities must be checked against the Australian Sanctions Regime.
- If screening identifies a sanctioned country, entity or person, the matter must be referred for legal or specialist advice before proceeding.
Defence export and technology transfer
- Assess whether goods, software, technology, data or services are controlled under relevant export-control legislation (for example, the Defence and Strategic Goods List or the Defence Trade Controls Act 2012.)
- Where export controls apply, assess the requirement for a Defence Export Control permit and lodge any required applications, seeking advice from Legal Services only where needed.
Foreign Influence Transparency Scheme (FITS)
Complete a FITS screening checklist at the start of any engagement that may involve foreign influence.
If the checklist indicates registration is required, obtain any necessary advice or confirmation from Legal Services before proceeding.
3.5 Appeals and escalations
If an FCR is not endorsed, the activity owner may submit an appeal with additional information.
Appeals are considered by the relevant decision-maker identified in the governance and delegations framework utilising the relevant consultation, decision and escalation pathways outlined in section 3.2.3.
Significant or institution-wide risks may be escalated through Adelaide University’s governance channels.
3.6 Training and awareness
Training and awareness are delivered through the University’s foreign compliance program, coordinated across relevant units.
Staff in internationally engaged roles, research supervisors and titleholders must complete foreign compliance training within 3 months of appointment.
Conditional FCR outcomes may require completion of additional briefings before commencing the activity.
Training completion is monitored, and FCR outcomes may be withheld until required training is completed.
Failure to complete training may result in activity suspension or withdrawal of foreign activity approval.
3.7 Monitoring, assurance and reporting
Decisions, endorsements, affiliations, conditions and expiry dates are recorded in the Foreign Compliance Register.
Matters presenting elevated or systemic risk are escalated in accordance with Adelaide University governance processes.
DFAT notifications are submitted in accordance with the relevant foreign arrangement assessment protocol.
Commencing 31 March 2026, a consolidated monthly report of all FCR submissions and final outcomes is prepared by Research Security for the Chief Security Officer and provided to the Deputy Vice Chancellor – International and External Engagement, the Pro Vice Chancellor, Global Partnerships, the Executive Director, Research Services, and the Deputy Vice Chancellor – Research and Innovation.
3.8 Breaches and non‑compliance
Non-compliance includes:
- failing to lodge an FCR when required
- starting or continuing an activity without endorsement or in breach of conditions
- providing false, misleading or incomplete information
- breaching sanctions, export-control, FITS or foreign-arrangements law or institutional requirements
- not completing required training.
Consequences for non-compliance include:
- Activities may be suspended or terminated.
- Matters may be referred for disciplinary action or external reporting where required.
- Remediation and lessons learned processes will be applied.
4. Who holds a responsibility within this procedure
Refer to the Delegation Policy for all delegations at Adelaide University.
4.1 Chief Security Officer
The Chief Security Officer is responsible for providing institutional leadership, oversight and accountability for Adelaide University’s foreign compliance framework. They must:
- oversee the implementation, maintenance and effectiveness of this procedure and the Foreign Compliance Protocol(s)
- ensure the formal FCR process is established, resourced and supported through the Adelaide University Foreign Compliance portal
- ensure that foreign compliance assessments, due diligence and legislative screening (including sanctions, export controls and FITS) are undertaken for activities requiring an FCR
- ensure that foreign compliance operations are appropriately staffed, trained and supported
- ensure that legislative compliance checks are undertaken for activities requiring an FCR
- review foreign compliance assessments and provide endorsement recommendations in accordance with the Delegation Policy
- provide written recommendations on specified FCRs to the Deputy Vice Chancellor – International and External Engagement before any endorsement outcome is communicated to the proposer
- provide the rationale for non-endorsement recommendations and discuss such recommendations with the Deputy Vice Chancellor – International and External Engagement (and Deputy Vice Chancellor – Research and Innovation in the case of research-related activities) as required
- ensure that decisions, endorsements, conditions, affiliations and expiry dates are recorded in the Foreign Compliance Register
- escalate high-risk, systemic or unresolved foreign compliance matters to the Deputy Vice Chancellor – International and External Engagement, Deputy Vice Chancellor – Corporate, and the Deputy Vice Chancellor – Research & Innovation
- act as Adelaide University’s primary liaison with Australian Government departments (for example DFAT, Defence, Home Affairs) and represent Adelaide University in sector-wide security and compliance forums
- oversee investigations and institutional responses following foreign-compliance breaches, including remediation and continuous improvement activities
- ensure secure records and documentation associated with FCR submissions, legislative checks and endorsement outcomes are maintained
- provide FCR outcomes and relevant supporting information to the appropriate portfolio owner (Global Partnerships or Research Services) and to the University’s Foreign Arrangements team where an activity may constitute a foreign arrangement
- commencing 31 March 2026, generate and verify consolidated monthly reports on FCR submission, endorsements, and outcomes to the Pro Vice Chancellor, Global Partnerships, the Deputy Vice Chancellor – International and External Engagement, and the Deputy Vice Chancellor – Research and Innovation, to support governance oversight and policy ownership responsibilities
4.2 Research Services must:
- undertake FAS notifications in accordance with the [Foreign Compliance Protocol] when FAS arrangements are identified.
4.3 The Office of Global Partnerships must:
- deliver foreign compliance awareness activities relating to international engagement, foreign arrangements, partnership development, and country-risk considerations with support from the Chief Security Officer
- support integration of foreign compliance requirements into partnership, international activity and global engagement training materials
- provide subject-matter input into training and awareness materials where international collaboration, partnership governance or foreign relationship matters are involved
- review foreign affiliation declarations provided by the Chief Security Officer within required timeframes and escalate complex cases for specialist assessment
- undertake FAS notifications in accordance with the [Foreign Compliance Protocol] when FAS arrangements are identified.
4.4 Deputy Vice Chancellor – Corporate, must:
- provide governance oversight and adequate resourcing to support foreign compliance functions
- receive escalations from the Chief Security Officer and Deputy Vice Chancellor – Research & Innovation and ensure that systemic or high-risk issues are tabled at Council or relevant governance committees when required
- consult with the Chief Security Officer, Deputy Vice Chancellor – Research & Innovation, and the Deputy Vice Chancellor – International and External Engagement where a disagreement endures between the parties in relation to an FCR outcome decision, prior to escalation.
4.5 Deputy Vice Chancellor – Research and Innovation must:
- exercise final endorsement authority for research and research-related foreign engagements, consistent with the Delegation Policy
- consider and determine appeals against FCR recommendations relating to research activities utilising the relevant consultation, decision and escalation pathways outlined in Section 3.2.3
- advise and seek to resolve with the Deputy Vice Chancellor – International and External Engagement where the FCR outcome decision departs from the recommendation of the Chief Security Officer
- escalate significant or unresolved decisions and risks, in consultation with the relevant College Dean(s), Research or Research Institute Director(s), the Deputy Vice Chancellor – International and External Engagement and the Deputy Vice Chancellor – Corporate, or other relevant senior staff, to the Vice Chancellor or Council.
- act as the institutional owner of this procedure.
4.6 The Deputy Vice Chancellor – International and External Engagement must:
- exercise final endorsement authority for foreign engagements including complex or high-risk FCRs relating to international activity, consistent with the Delegation Policy
- chair the University’s Global Strategy Committee
- receive escalations from the Chief Security Officer about foreign-engagement risks that are not research-related as described in section 3.1
- approve the Chief Security Officer’s FCR outcome recommendations, or otherwise advise and seek to resolve with the Deputy Vice Chancellor – Research and Innovation, before final determinations are communicated
- escalate significant or unresolved decisions and risks, in consultation with the relevant College Pro Vice Chancellor(s), the Deputy Vice Chancellor – Research and Innovation, the Deputy Vice Chancellor – Corporate, or other relevant senior staff, to the Vice Chancellor or Council
- consider and determine appeals against FCR recommendations for foreign arrangements other than research-related activities, utilising the relevant consultation, decision and escalation pathways outlined in section 3.2.3.
4.7 Deputy Vice Chancellors (Academic, People & Culture), Provost, and others as relevant), must:
- ensure that activities within their portfolios comply with this procedure
- consult in relation to appeals lodged under section 3.5 relating to their portfolio area
- provide support for resolving contested, complex or high-risk matters.
4.8 Global Strategy Committee must:
- provide governance oversight for international engagement, foreign arrangements and global partnership strategy.
- receive a consolidated quarterly summary of FCR and Foreign Arrangement Assessment outcomes, significant trends, systemic risks and compliance issues.
4.9 College Pro Vice Chancellors, College Dean(s), Research, and Research Institute Director(s) must:
- consult as required in relation to escalating significant or unresolved foreign compliance risks affecting their college or institute, in accordance with this procedure and the Delegations Policy
- support implementation of endorsed risk controls or conditions within their college or institute following escalation.
4.10 Line managers and supervisors must:
- ensure staff under their supervision understand and follow this procedure
- confirm that relevant FCRs and declarations are completed before work commences
- encourage completion of required training and provide support for compliance activities.
4.11 Staff, students and titleholders must:
- identify potential foreign compliance activities and triggers listed in section 3.1
- complete and submit FCRs and declarations when required
- undertake required training and comply with any approval conditions
- immediately report suspected non-compliance to the Chief Security Officer.
5. Definitions used in our procedure
Please refer to our Adelaide University glossary for a full list of our definitions.
Foreign arrangement means a written agreement, contract, understanding or undertaking between Adelaide University and a foreign entity, whether legally binding or not.
Foreign Arrangement Scheme (FAS) Arrangement includes, as defined in section 9(1) of Australia’s Foreign Relations (State and Territory Arrangements) Act 2020, any written arrangement, agreement, contract, understanding or undertaking whether or not it is legally binding entered into with a Foreign Entity.
Foreign engagement means any interaction, understanding or relationship, written or unwritten, between Adelaide University (or its staff or students acting in that capacity) any foreign organisation including foreign governments, foreign government-linked entities, foreign universities, and foreign commercial companies. A foreign engagement may include a written arrangement that is also a Foreign Arrangements Scheme (FAS) arrangement.
Foreign influence means activities by, or on behalf of, foreign governments (and their entities) that seek to shape deliberations or decision-making. When conducted openly and transparently, such activity is a normal aspect of international relations and can contribute positively to public debate.
Graduate research student means a student enrolled in a graduate research program. It does not include students enrolled in coursework programs that contain a research component, such as an honours program.
Prospective student means a person who has contacted Adelaide University, or an agent representing Adelaide University, with the intent of becoming a student.
Student means a person enrolled in an enabling program, award or non‑award coursework study, a research program, or a short course or microcredential at Adelaide University.
Titleholder means any person upon whom Adelaide University has conferred an honorary academic title.
6. How our procedure is governed
This procedure is categorised, approved and owned in line with the governance structure of Adelaide University and the offices and officers listed below.
| Parent policy | Foreign Compliance Policy |
|---|---|
| Policy category | Corporate |
| Policy owner | Deputy Vice Chancellor – International and External Engagement |
| Procedure owner | Deputy Vice Chancellor – Research and Innovation |
| Approving authority | co-Vice Chancellors/Vice Chancellor and President |
| Responsible officer | Chief Security Officer |
| Effective from | 1 January 2026 |
| Review date | [3/4/5 years after date this version is approved, TBC] |
| Enquiries | Interim Central Policy Unit |
| Replaced documents | Foreign Compliance Policy and Procedure (Interim) |
7. Legislation and other documents related to our procedure
Refer to the [Delegation Policy] for all delegations at Adelaide University.
8. History of changes
| Date approved | To section/clauses | Description of change |
|---|---|---|
| 6 February 2025 | N/A | Interim Foreign Compliance Policy and Procedure. |
| 19 December 2025 | N/A | Interim policy and procedure split into two documents. FCR processes placed in separate procedure for oversight by Research and Innovation. Full rewrite and reformatting of the original draft to comply with the Adelaide University Writing Guide Version 2.3. Document structured using the approved policy template and policy hierarchy standards. |
At the time of writing, Adelaide University’s organisational structure, position titles, and committee names have not been confirmed. Square brackets [ ] indicate placeholders for these details. Brackets are also used to identify policy elements that are subject to further decision-making or confirmation. These will be updated once final decisions are made.