Information & Documentation Requirements

In establishing the FITS, the Australian Government is signalling the potential risks that can accompany any engagement with foreign entities and the need for certainty about our international partners. It is important to be clear about any activities that could be considered to be undertaken on behalf of the foreign entity.

This may mean that you need to gather specific information to be able to identify whether you have incurred, or will incur, a registration obligation. Even if you do not have a registration obligation, you must keep a record of the information you used to reach this decision.  You should record what you know about your collaborator, the nature of your involvement with that entity and the activities planned.

If an activity or arrangement is registered, there are ongoing obligations under the FITS. These include a requirement to report any material changes in circumstances of the activity of the arrangement, including updating information on the register to ensure that it is not misleading or inaccurate. Information that is, or will become, inaccurate or misleading must be corrected within 14 days.

Registrations need to be renewed every 12 months if the registrant continues to undertake registrable activities on behalf of a foreign principal. If a registration is not renewed after 12 months, it will automatically expire.

The following information and supporting documents should be collected and saved in the University’s approved recordkeeping system:

Information about foreign principals

  • Name, nationality and country of residence or business of the foreign person or entity with whom you are dealing, or proposing to deal;
  • Details of the foreign person or entity’s business or professional activities, including URL addresses for any identified online presence or information; and
  • Any information provided by, or known about, the foreign person or entity’s connection with foreign government or foreign politics.

Refer to the Foreign Compliance website for due diligence resources, or seek further details from the relevant person or an authorised representative of the organisation, institution or corporation.

Information about registrable arrangements or activities

  • Any contract, proposal or correspondence relating to the arrangements, or the nature of your collaboration with, the foreign person or entity;
  • Details of any payment or consideration that you or the University may stand to receive under the arrangement or collaboration; and
  • Details of any activities you have undertaken or propose to undertake in connection with your arrangement or collaboration, which involve communication or engagement with the Australian Commonwealth government, its departments, agencies or officials.

The information you collect will help you decide whether a foreign engagement is registrable under the Scheme. To seek further advice on your registration obligation, please complete the foreign engagement compliance review form.

Foreign engagement compliance review