Frequently Asked Questions
These FAQs will be revised and supplemented from time to time. However, readers should be aware that circumstances or applicable laws may have changed since the last revision date. Faculty and staff are responsible for following up with the Yale offices mentioned in these FAQs to obtain the most current information.
These FAQs are addressed to all Yale faculty and staff. If you are a business manager and are asked for assistance in an area outside your expertise, please contact the central Yale office in the relevant area for further information and guidance.
International activities described in these FAQs generally are those which take place exclusively outside the U.S. Issues related to admitting, hosting or hiring international students or scholars or international activities on campus in New Haven are not within the scope of these FAQs.
Human Resources/Working Abroad
Both Yale Health (YH) and Aetna provide coverage overseas. Yale Health coverage applies, however, only for urgent or emergency care. Urgent/emergency services are for non-routine or non-preventive conditions needed in order to prevent the serious deterioration of a member’s health following an unforeseen illness, injury or condition.
In a medical emergency, seek care and contact your health plan and/or UnitedHealthcare Global as soon as possible. It is best if you contact your medical plan provider in advance if possible, but advance notice in not a requirement for coverage. Please refer to the appropriate section below for additional information on coverage from YHP, Aetna, and UnitedHealthcare Global. If the local hospital requires payment upon treatment, UnitedHealthcare Global could either help to facilitate payment or they could issue a payment guarantee to the hospital.
- Yale Health
In an emergency, seek care and notify Yale Health Care Coordination ((203) 432 7397) within 2 business days. Refer to the YHP Member Handbook or for policy details.
Employee members of Aetna have medical insurance coverage while traveling overseas. Coverage mirrors that provided to the employee for healthcare received in the U.S. Members are responsible for paying for medical services and submitting claims to Aetna for reimbursement. Refer to Yale’s HR Benefits webpage to access Aetna plan documents.
- UnitedHealthcare Global (formerly FrontierMEDEX)
Yale also provides a special travel service that can help in the case of a medical emergency or problem overseas. If a serious injury or illness has occurred and treatment at a medical facility is not available, contact UnitedHealthcare Global using the appropriate toll free number for the country you are visiting (see back of UnitedHealthcare Global card or UnitedHealthcare Global web page) or contact the U.S. UnitedHealthcare Global office directly at (410) 453 6330. They will assist, monitor and coordinate your situation until it has been resolved (or you are no longer in danger). Be sure to travel with your UnitedHealthcare Global card for emergency contact numbers. Additional information is available on the International Travel page of this website. Note: Yale’s membership with UnitedHealthcare Global does not include travel health insurance and, therefore, medical emergencies should always be reported to your personal health care provider.
- Travel Health Insurance
If you are not covered abroad, or have incomplete coverage, you may purchase health insurance that provides coverage while you are overseas. Two such programs are offered by HTH Worldwide and UnitedHealthcare Global, or consider using an online tool such as SquareMouth to compare and identify appropriate international travel health insurance coverage. The International Operations & Compliance Committee has not reviewed the information on the SquareMouth website to verify its thoroughness or accuracy and therefore travelers are advised to do their own due diligence before using this site and purchasing insurance.
- Long Term Overseas Assignments
If you will be overseas for a semester or longer, Yale has a special plan that can provide comprehensive medical coverage for employees while overseas. To learn more or enroll in this plan, please contact the Yale Employee Service Center in advance of your travel.
Yale employees who are normally resident in New Haven may travel outside the U.S. for purposes of conducting Yale business but may be required to obtain an entry visa or a work permit.
Although certain brief visits abroad for informal meetings may be classified by a particular country as tourism, it is advisable to check on the visa and work permit requirements in the country to which you are traveling well in advance of your trip. If you are traveling outside the U.S. to conduct Yale work (e.g. teaching a course, conducting collaborative research at another university, leading a Yale travel program), you are strongly advised to investigate the need for a visa and work permit well in advance of your trip.
Traveling without an appropriate visa or permit may result in a denial of entry, deportation or the imposition of fines by the local country.
If you are not a U.S. citizen, you will encounter additional issues and should obtain specific advice to ensure your timely return to the U.S. The embassy or consulate of the country to be visited can provide information about entry requirements.
Information about the visa and permit requirements of a particular country are available at the embassy or consulate for the country. You may also utilize the visa services company CIBT, who has been engaged by Yale to offer visa services to employees and students and is accessible through Yale Travel Management.
If a Yale employee is relocating outside the U.S. for purposes of conducting Yale business for a period of time in excess of one semester, such employee should consult his or her business manager. A variety of immigration, taxation and benefits issues will be raised by a long-term stay outside the U.S. Consult the Toolkit’s HR Section for further guidance. Yale employees who are in the U.S. on non–immigrant visas should consult with the Office of International Students and Scholars about any plans to be outside the U.S. for a semester or more.
The Yale University International Travel Policy for Yale College Students applies to all Yale College students who wish to undertake international travel funded by Yale, awarded credit by Yale, or in connection with a trip abroad by a recognized student organization. The Deans of the Schools may also establish policies and practices that apply to members of their respective communities.
Several University policies apply to business travel. Search the University’s policies by topic using the term “Travel.”
The University strongly encourages all members of the University community who are contemplating travel abroad to review thoroughly and to familiarize themselves with the political, health, crime, and other safety-related conditions prevailing in any country and specific locations within it. Please consult the Travel Section for additional information.
Yale may engage a consultant who resides outside the U.S. to perform consulting work on a Yale project only if that person is properly classified as a “consultant” (as opposed to an employee) under Yale Policy 3210, Contracting for External Consultants and Other Professional Services. The risks of misclassifying a person as a consultant are significant and, if you have any doubt about such classification, please contact the Yale Tax Department at 203-432-5530. For additional considerations, visit the HR Section of this website.
For a properly-classified consultant, the standard-form Yale consulting agreement (Yale University Standard Professional Services Agreement, Form 3210.1) should be used as the starting point for documenting the relationship. You should contact Yale Procurement for assistance.
Yale will not be able to hire people outside the U.S. as employees without observing the local employment regulations and the other laws of the country where the individual will be working. This will typically require that Yale have a branch or registered office within the country and a payroll function that is in compliance with all local taxation and social benefits laws. It may be possible to use the services of a third-party personnel agency within the local country to engage personnel or to second (i.e. “loan”) an employee to a local academic institution involved with the relevant Yale project.
Please refer to the International Tax website for information related to required tax forms as well as the U.S. reporting and withholding requirements.
If you have questions, please consult your business manager who can coordinate with Human Resources and the Office of General Counsel, as necessary.
In most cases, you can bring your laptop or other electronic device to another country. However, in certain situations, taking a laptop computer or other electronic device outside the U.S. may be regarded as an “export” subject to regulation by the U.S. government under the U.S. export control laws. Such “exports” may require a license from the U.S. government, particularly if you are traveling to a country with which the U.S. has an embargo or your device contains encryption software, unpublished data covered by a technology control list maintained by the U.S. government, data with potential military use or data relating to weapons of mass destruction.
So long as you are not traveling to an embargoed country and do not have encryption software, a license should not normally be required if your electronic device is of a type that is generally available for sale from commercial vendors, is kept under your immediate control when outside the United States and is brought back to the United States within one year of the initial departure.
Encrypting laptops and other portable devices is an effective way to protect sensitive data. Unfortunately, many countries, including the US, restrict or prohibit the use of encrypted devices. Under U.S. law, an encrypted device such as a laptop can be brought overseas but it must return to the U.S. within one year and during the overseas trip, the owner “must retain effective control and ownership.” Furthermore, under U.S. law, you cannot bring an encrypted device to certain countries such as Cuba and Sudan.
Other countries may restrict your ability to bring and use an encrypted device in the country (e.g., China). It is possible that any encrypted devices you bring without advance permission from said country may be confiscated upon arrival.
Consider one of the following alternatives if you are traveling to a country with encryption restrictions:
Leave your encrypted laptop or other encrypted portable device at home. Ask if your school or department can loan you an unencrypted laptop for the trip. Be sure the device’s hard drive does not contain sensitive information prior to departure and ensure that any data you save on its hard drive during your travels is removed immediately upon your return.
For longer-term trips, it may be possible to obtain permission from the foreign country to bring in an encrypted device. In China, for example, visitors may apply in advance for licenses to bring in and use an encrypted laptop. Licensing can take several weeks to complete, so must be researched and initiated well ahead of departure.
To learn whether your travel destination restricts or prohibits the use of encrypted devices and/or whether it is possible to apply for permission to bring an encrypted device, contact the Office of the General Counsel at (203) 432-4949. For additional considerations about traveling with electronic devices, click here.
For information about travel health, including consultations, vaccinations, medications, and the Yale Travel Clinic, visit the Travel Clinic at Yale Health.
Travel to certain countries will require one or more vaccinations or the taking of a course of medication to protect against diseases such as malaria, hepatitis A and B, encephalitis, meningitis, polio, rabies, tetanus, typhoid, yellow fever and influenza. You are strongly advised to contact the Travel Clinic at Yale Health at least 6 to 8 weeks prior to your trip to obtain medical advice and start any necessary course of treatment.
Knowledge is the best protection. Visit the International Travel Section of this website and review the Safety and Security section of the International Travel Toolkit. Follow the traveler preparation steps and consult the resources listed on that website. Register your travel so Yale can assist you in an emergency, familiarize yourself with your destination and make sure you have your UnitedHealthcare Global card with you. The UnitedHealthcare Global online member center provides comprehensive destination information. Please review it before you leave to learn as much about your destination as you can.
Please follow each of the steps listed below in the following order:
- Where serious injury or illness has occurred, immediately seek medical treatment at the closest medical facility. If medical service is not available, contact UnitedHealthcare Global for assistance (click link or call collect 1-410-453-6330).
- Call the University 24-hour security office 203-785-5555. Notify the contact person in your program, department, or school.
- For medical emergencies, notify Yale Health Acute Care (203-432-0123) or your personal health care provider.
- Contact the nearest U.S. Embassy or consular service.
- Contact UnitedHealthcare Global (click link or call collect 1-410-453-6330) to inform them of your emergency. UnitedHealthcare Global will assist, monitor, and coordinate your situation until it has been resolved or you are no longer in danger.
Be sure to register your travel plans on the Yale Travel Registry so we can contact you to provide help during an emergency situation.
The process for arranging a wire transfer is described in University Procedure 3401 PR.06, Requesting a Wire Transfer. Wire transfer requests made to pay an invoice should generally be made in the same currency as stated on the invoice. Please refer to the aforementioned procedure, or contact Treasury Services at firstname.lastname@example.org regarding wire transfer payments.
If you believe a Yale bank account outside the U.S. is required, please contact the Office of the Controller, Treasury Services (203-432-4474 or email@example.com) and provide a full description of the related Yale program and the purpose and duration of the proposed account. This office will analyze the proposal and coordinate with other Yale offices, as necessary, and respond to you.
In most cases, Yale will be unable to open a bank account abroad unless Yale has first taken formal steps to legally register a subsidiary or branch of Yale in the specific country.
A University employee should NOT open a bank account under his or her name in order to conduct University business.
University employees should avoid carrying cash beyond that necessary for immediate and ordinary personal expenses while traveling. Please see Obtaining Cash for Yale Activities Abroad for guidance on approved options for obtaining cash or cash equivalents in support of Yale-related travel and Yale activities conducted outside the U.S.
An individual traveling to or from the U.S. with cash (including traveler’s checks) in excess of $10,000 must declare the amount to U.S. Customs. Many other countries restrict the amount of cash that an individual may bring in or out of the country. One consequence of noncompliance with these requirements may be confiscation of the cash. Information about other countries’ currency restrictions may be found on the U.S. State Department website.
The Yale Purchasing Card does not normally support cash withdrawals from ATMs. If an urgent need for cash to fund Yale activities arises while you are traveling, please contact the Office of the Controller, Treasury Services, at (203) 432-4474 or firstname.lastname@example.org.
The University issues travel advances only to travelers who are ineligible for the Yale Purchasing Card or when extended travel or unusual circumstances are involved. Please refer to Policy 3305 for additional information or contact your business office.
Purchasing Cards or “P-Cards” are commercial MasterCards and may be used wherever MasterCard is accepted by an international vendor. Please contact Yale Procurement for more information.
The Purchasing Card is the preferred method of payment for all travel purchases, including airline and train tickets, hotel reservations and payments, conference registration fees, meals, and other business expenses. You may want to check with your business office or cardholder agreement before departure for limits on amounts and types of transactions.
Leasing space for Yale programs or student housing must be coordinated with the Office of the General Counsel and the Yale Risk Manager. Any proposed location should be fully reviewed by a Yale representative using a Yale health and safety checklist.
It is less likely that Yale would purchase real property outside the U.S., and to do so would require approval of the Yale Corporation.
University employees should not lease or purchase real property used to conduct Yale activities in their own name. To do so circumvents Yale policies and procedures designed to protect the institution and its students and employees and may subject the individual to personal liability.
Equipment may be purchased or leased outside the U.S. on behalf of Yale through Yale Procurement. Any legal documentation (e.g. a lease or other contract) should be reviewed by Yale Procurement and the Yale Risk Manager.
University employees should not lease or purchase equipment used to conduct Yale activities in their own name. To do so circumvents Yale policies and procedures designed to protect the institution and its students and employees and may subject the individual to personal liability. In the event you are presented with a situation where individual purchase of equipment is the only available alternative, please contact your business manager to ensure that appropriate arrangements are made regarding title, insurance and other matters relating to such equipment.
You may rent a vehicle outside the U.S., but rental agencies will require that you do so under your own name. You may need to obtain an international driver’s license prior to your trip in order to rent a vehicle. You may visit any office of the Automobile Association of America (AAA), regardless of your membership status, to obtain an international driver’s permit or visit the AAA website.
Yale’s insurance coverage will only apply to vehicle rentals for Yale business taking place in the contiguous United States. In these 48 states, you may waive the collision damage coverage. If you are renting a car in any other location, you must purchase liability and physical damage insurance from the rental agency. For additional information, visit the Yale Travel Management webpage.
University employees should not purchase vehicles used to conduct Yale activities in their own name. If you are faced with a situation where an individual purchase seems required, please contact your business manager to ensure that appropriate arrangements are made regarding title, insurance and other matters relating to such vehicle.
Yale may obtain services or products from a non–U.S. business through Yale Procurement. Yale Procurement can work with you to locate the right vendor or assist you in dealing with a previously–identified vendor. Once the appropriate vendor is identified, Yale Procurement will review and process the agreement or invoice.
Please refer to International Tax for information related to required tax forms as well as the U.S. reporting and withholding requirements.
To read more on engaging a consultant outside the U.S., visit the HR Section.
Most proposed relationships with non-U.S. entities (e.g. another university, a hospital or a non-governmental organization) will require a series of coordinated reviews and approvals within Yale. Certain other agreements are frequently recurring and established procedures are in place for processing them. For example, material transfer agreements are handled by Grants and Contracts Administration, and international purchasing and engagement of consultants is handled by Yale Procurement.
General agreements including, without limitation, proposed collaboration or inter-institutional agreements (frequently referred to as “MOUs”) should first be fully reviewed and approved within the relevant school or division at Yale. Once the Dean’s Office has approved the proposed relationship, it should be directed to the Office of the General Counsel and the Office of International Affairs for review. If the relationship involves sponsored research, it should be directed to the Office of Sponosred Projects.
The Office of the General Counsel or the Office of Grant and Contract Administration (depending upon the presence of sponsored research) will take the lead in drafting the relevant agreement and coordinating with other Yale offices as required. Offices that may play a role in the review process include the Office of the Provost, the Tax Department, the Yale Risk Manager, and the Controller’s Office.
Once an agreement has been drafted and approved, the draft will be sent to the international entity for discussion. Such agreements must be signed by an authorized Yale signatory.
Export activity that occurs in the course of travel, research collaborations, or expenditures (as well as the actual transfer of research results, data, equipment, or materials) outside of the U.S. may create export control concerns for the University and members of the University community. Export controls are U.S. laws which regulate the “export” of certain controlled technologies, services, and information to foreign nationals, foreign entities or foreign countries for reasons of national security and foreign policy. An export could be the actual shipment outside of the U.S. of controlled equipment or materials or the disclosure of information or technical data related to controlled equipment or materials outside the U.S or inside the U.S. to a foreign national. “Technology transfer” activities which could trigger export control concerns include scientific, engineering and academic exchanges, and international meetings and visits.
The U.S. also regulates export activity through targeted restrictions administered by the Department of Treasury’s Office of Foreign Assets Controls (OFAC). Certain kinds of transactions with certain individuals, entities, and countries (e.g., Cuba, Iran, N. Korea, Sudan, or Syria) are prohibited without a license from the U.S. government, unless an exception applies.
The University has administrators in Grants and Contracts Administration (contact email@example.com), who can help faculty and staff determine if their research and educational activities involve technologies or transactions subject to U.S. export and OFAC controls.
Please be aware that the laws of countries other than the U.S. may govern your activities and may provide additional import or export restrictions. It is your responsibility to obtain relevant information applicable to your activities and then to follow up with Grants and Contracts Administration or the Office of the General Counsel for advice.
The privacy laws of other countries can be more rigorous that in the United States, and researchers must take care to become familiar with the requirements of local jurisdictions when gathering information from local citizens. The European Union, in particular, has developed extensive statutory protections for the personal information of its citizens that exceed the protections that the U.S. requires. Strict guidelines control when personal information can be gathered, what constitutes a legitimate purpose for collecting data, and whether personal information can be transferred to third parties. A copy of the European Union’s directive is available.
The importation to the U.S. of biological, chemical or hazardous materials may require permits and compliance with certain regulations. For example, the importation of certain etiological agents, hosts or vectors of human diseases requires a permit from the CDC. If you wish to import a select agent or toxin, you need to register with the CDC and comply with the regulations governing the use, transfer and possession of select agents and toxins.
The USDA’s Animal and Plant Health Inspection Service (APHIS) controls the importation of many items, such as live animals and animal embryos. Import permits from APHIS are required for the importation of plant pathogens (bacteria, viruses, fungi, mycoplasms and nematodes) as well as for any fruit and vegetable samples.
In addition to U.S. legal requirements, the country from which material or samples are exported may require that a permit be obtained. Many countries are increasing their surveillance and other enforcement activity in areas where exports implicate national cultural or financial interests. Faculty and staff should research these requirements prior to conducting any collection, excavation or other research activities in the relevant country.
Faculty and staff should also be aware of the ethical and legal issues related to the acquisition of significant works of art, artifacts and antiquities from countries outside the U.S. Several international treaties address these issues including:
- The Hague Convention for the Protection of Cultural Property in the Event of Armed Conflict, 1954
- The UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property, 1970
- The UNIDROIT Convention on Stolen or Illegally Exported Cultural Objects, 1995
More information on this topic is available here.
Guidance on the import of biological, chemical or hazardous materials can be obtained from Yale Environmental Health & Safety. Please direct other questions to the Office of General Counsel at (203) 432-4949.
Laws and Policies
Many activities will raise different legal or compliance issues when they are conducted outside the U.S. The following list is not exhaustive:
- Purchasing goods and services
- Working in another country or hiring employees in another country
- Retaining full or part time consultants in another country
- Paying taxes or social insurance
- Securing visas or work permits
- Obtaining permits to conduct research activities
- Removing plants, animals or research materials from a country and bringing them to the U.S.
- Wiring money
- Renting space for programmatic activities or housing
- Renting or owning vehicles
- Traveling to countries subject to U.S. government travel advisories or warnings, or affected by U.S. government sanctions or embargoes
- Traveling to countries that may require specific vaccinations or medication
- Exporting or importing equipment, materials, samples or data
- Traveling with a laptop or other electronic device
- Protecting intellectual property ownership
- Protecting the privacy of data
- Using the Yale name
- Responding to requests for bribes or similar payments
- Developing and maintaining long term relationships with educational or non-governmental entities or governmental bodies
- Entering into any type of business relationship with a person or entity abroad
- Responding to an inquiry from a journalist outside the U.S.
The U.S. Foreign Corrupt Practices Act makes it illegal to corruptly offer, promise or give anything of value to a foreign official or to a foreign political party or official of such party to obtain influence, induce an action or obtain an advantage. The Act will also apply if you use an intermediary to effect such a payment. The Act provides for criminal and civil penalties and will not permit Yale to reimburse any employee for penalties incurred, even inadvertently, under the Act.
It is important to note that many non-U.S. universities and hospitals are state-owned and run, thus making employees of these entities “foreign officials” for purposes of the Act.
For additional guidance in analyzing the Act or considering specific payments or gifts, please visit the Restricted Activities section of the International Toolkit or contact the Office of General Counsel.
The U.S. Foreign Corrupt Practices Act will apply to a gift (i.e. something of value) to a foreign official or political party if the gift is made to obtain influence, induce an action, or obtain an advantage. Clearly, this prohibition will apply to all governmental officials; in addition, it will apply to employees of state-run universities, hospitals and other entities who are likely to be considered “foreign officials” for purposes of this law. Click here to read more about this topic.
The safest practice is to avoid giving gifts to governmental officials and colleagues outside the U.S. in connection with Yale work. If a gift is culturally important, appropriate, and not made to induce an action or obtain an advantage (regardless of the value of the gift), it may be made under the following circumstances. Gifts of nominal value purchased with University funds and publicly presented to foreign officials as part of conventional hospitality or as a token of appreciation in the context of a visit are generally acceptable if given to highlight Yale and work done with Yale. Safest are those that are tied directly to Yale and its mission, e.g., a copy of a book by a faculty member; a scarf bearing a Yale insignia; or a photograph of the Yale campus. The more personal the gift, the less likely such a payment can be defended in this way. Any such gifts should be valued at $100 or less in order to avoid raising any questions about their propriety under law and to be consistent with University policy. See Yale Policy 3303, Gifts from University Funds, section 3303.4, Institutional Gifts.
Use of the Yale name raises reputational issues and potential liability issues for Yale. If the Yale name is used, for example, to indicate sponsorship of a conference, it would be appropriate for Yale to inquire about the premises, insurance coverage and other aspects of the conference. Any use of the Yale name in signage or for activities such as conferencing requires prior review by the Trademark Licensing Office and the Yale Risk Manager.
Ongoing Yale research or other programs outside the U.S. may lead to a desire to use the Yale name in print or on signage. A faculty member may propose that Yale sponsor a conference or other activity outside the U.S., perhaps in conjunction with another institution. These uses of the Yale name, and other similar uses, will require prior review by the Office of the Secretary at Yale.
Individual scholarly activities such as attending conferences, meeting with colleagues at other institutions and limited research visits should not require any use of the Yale name (except, for example, to factually identify a person as a Yale faculty member at a conference).
U.S. law prohibits individuals and entities (including Yale) from participating in a boycott that is not approved by the U.S. government. The main unsanctioned boycott to which these laws have been applied is the Arab boycott of Israel. A boycott may take various forms including refusing to do business with the boycotted country and discriminating on the basis of race, religion or national origin.
A boycotting country is any country that is on the list maintained by the U.S. Secretary of the Treasury. The current list includes Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United Arab Emirates, and the Republic of Yemen.
All Yale activities, whether domestic or international, will be subject to the Yale nondiscrimination policy.
Please contact the Office of General Counsel (203-432-4949) or the Tax Department (203-432-5530) to obtain advice and ensure compliance with the IRS reporting requirements regarding boycotts if any of the following situations apply:
- You are conducting or would like to conduct Yale or personal scholarly activities in a boycotting country; or
- You have entered into an agreement or are asked to enter into an agreement to (A) refrain from doing business with or in a country which is the object of an international boycott or with the government, companies or nationals of the country, (B) refrain from doing business with any U.S. person engaged in trade in a country which is the object of an international boycott or with the government, companies or nationals of that country, (C) refrain from doing business with any company whose ownership or management is made up, all or in part, of individuals of a particular nationality, race, or religion, or (D) refrain from employing individuals of a particular nationality or religion.
In the event that you are contacted by a non-U.S. government in any respect including without limitation receipt of any complaint or other allegation of misconduct, please immediately contact the Office of General Counsel. In the event that anyone attempts to serve you with notice or process in connection with any legal action against Yale, you should not accept such notice or process and you should immediately contact the Office of General Counsel at 203-432-4949. For additional information, please consult Yale General Counsel, Service of Process.
Permits or licenses are often required in order to conduct field work at sensitive sites, deal with antiquities, collect samples of biological materials, etc. If you maintain or require a permit or license to conduct Yale activities outside the U.S., you should coordinate through your business manager to notify and work with the Office of General Counsel and, depending upon the subject matter of your activities, other offices at Yale (e.g. Office of Environmental Health and Safety, the Office of Grants and Contracts). Any permit or license application on behalf of Yale must be signed by an authorized signatory.