About Foreign Sources Reporting

To meet the university’s obligations for foreign sources reporting, UNLV must collect data on all gifts from and contracts with foreign entities campus wide, regardless of the exchange of monies. In collaboration with the UNLV Office of General Counsel, campus units have been identified as potential entry points for incoming gifts from and contracts with foreign entities including but not limited to Memorandums of Understanding (MOUs), cooperative agreements, and non-disclosure agreements.

Roles and Responsibilities

Reporting Process

A survey is emailed by QAFC directly to Foreign Sources Reporting Designees. Reporting Designees are required to respond to the survey, including when there is no activity, and report all activity for the covered reporting period by the stated deadline. The Foreign Sources Reporting Lead in QAFC will aggregate, assess, and submit qualifying data to agencies requesting foreign sources reporting.

Reporting Timeline

Reporting Timeline

Definitions

The definitions below apply only for the purposes of foreign sources reporting; they do not define how these terms are generally used or understood at UNLV.
  • “Foreign source”means any one of (A) a foreign government, including an agency of a foreign government; (B) a legal entity, governmental or otherwise, created solely under the laws of a foreign state or states; (C) an individual who is not a citizen or a national of the United States or a trust territory or protectorate thereof; and (D) an agent, including a subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source (which UNLV interprets as including any situation in which a person or entity is making a gift to the University or entering into a contract with UNLV under the direction and control of a foreign source).
  • “Contract”means any agreement for the acquisition by purchase, lease, or barter of property or services by the foreign source, for the direct benefit or use of either of the parties. UNLV interprets the definition of “contract” as covering only those contracts that involve payments to the University in exchange for goods and services (that is, money-in contracts). Tuition payments to the University from foreign sources are covered. UNLV collects information regarding all contracts regardless of whether they have a monetary value (for example, memoranda of understanding, non-disclosure agreements, data sharing agreements, incoming material transfer agreements, faculty, or student exchange agreements, etc.).
  • “Gift” means any gift of money or property. UNLV has interpreted “gifts” to exclude pledges or gift agreements. Only the actual receipt of money or property should be reported.

Contact

For more information contact the Foreign Sources Reporting Lead:

Laura Schneider, Sr. Compliance Analyst
Quality Assurance & Financial Compliance
Division of Business Affairs
laura.schneider@unlv.edu