Visa Sponsorship Letter Best Practice Procedure Tracy Horridge Export and Security Administrator Thermo Scientific Portable Optical Analysis Wilmington.

Visa Sponsorship Letter Best Practice Procedure

Tracy Horridge

Export and Security Administrator

Thermo Scientific Portable Optical Analysis

Wilmington MA

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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