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