Payments & Banking

When planning your international activities it is important to consider how to compliantly make payments for services and manage your money. This page guides compliant payments and banking when conducting business abroad.

Making Payments

If you will be paying an individual for services outside the U.S., depending on the scope of work, relationship between parties, and individual circumstances, you may need to engage them as either an independent contractor (IC) or as an employee.

For individuals being engaged for work on a project that is limited in time and scope, who do not have a current or prior employment relationship with Penn, and who will not perform work considered to be that of a Penn employee, it may be appropriate to engage them as an IC. The final worker classification determination will be made after a complete review of the engagement. All requests must be submitted well in advance of the anticipated start date of services. Visit our International Independent Contractor page for more information.

Note that single-member and sole proprietor LLC’s may, depending on their legal structure for tax purposes in the country of service, be considered individuals and subject to the same guidelines as other ISP’s.

For individuals being engaged in employment roles, including longer-term and higher-risk engagements not appropriate to be treated as IC’s, they will need to be hired compliantly onto a local payroll in the country of service. As Penn is a US employer without the right to employ individuals in other countries on our US payroll, a third-party employer of record may be required, at an additional cost to your department. To engage an employee abroad, complete an Employment Abroad Request at least 4-6 weeks prior to the start date. GSS will review your request and assist you with setting up the employment arrangement under applicable laws.

If you will be paying for goods or services provided by a foreign company or corporate entity outside the U.S., all payments must be handled through the Penn Marketplace. Your department is responsible for requesting a new supplier in the Marketplace, as needed, and ensuring they are registered and approved for payment.

Instructions for non-U.S. based entities completing their supplier registration in the Penn Marketplace are available in BEN Helps.

As a general rule, Penn does business in USD, and payments should be made in USD when possible. If a payment must be made in a foreign currency (FC), the FC request should be submitted as a non-PO payment request in the Marketplace.

Honoraria payments are distinct from service payments and are designed to confer distinction or symbolize respect for the recipient. They should not be a negotiated amount, should not correspond to an amount the individual has requested, nor should any invoice be received. The activity the recipient is being paid for may not last more than 9 days. Honoraria payments are given at the discretion of the University only.

In most cases, honoraria payments are paid in connection with a visit to Penn, though in some cases an honorarium may be paid to an individual outside the U.S. In these cases, an honorarium can be considered foreign source income so long as the individual did not come to the U.S.

Payment of honoraria to individuals outside the U.S. should be processed as non-PO payments through the Penn Marketplace in accordance with Honoraria Payments guidelines.

Note that proof of U.S. visa status is only required for foreign nationals who traveled to the U.S. to complete the activity.

When Penn pays the travel costs for a visitor or collaborator, the best practice is for the Penn department to book the travel (flight, hotel, etc) on behalf of the guest.

Alternatively, and subject to your School/Center’s Guest Travel Reimbursement policy, it may be possible to reimburse the guest for travel expenses via the Guest Travel Reimbursement process.

The Guest Travel Reimbursement (GTR) form must be used to support travel expense reimbursement for Penn guests and should be processed as non-PO payments through the Penn Marketplace in accordance with Guest Travel Reimbursements guidelines.

Guest Travel Reimbursements may not be used for Independent Service Providers (ISP’s) or Limited Engagement recipients. Any travel costs should be reflected within their fee structure.

Payments to participants in a clinical trial or survey as part of a research study should be made in accordance with Penn’s Payment of Human Subject Fees policy.

The preferred method of Human Subject payments is via the Greenphire ClinCard. However, please note that the Greenphire card is only available in USD. Therefore, Human Subject payments made to individuals outside the U.S. should be handled as non-PO payments via the Penn Marketplace.

Banking Considerations

Whenever possible, payments should be made in accordance with Penn’s preferred payment mechanisms. Cash payments should be limited to instances when another compliant payment method is not possible.

For handling cash payments in a cash economy, you may need to pursue one or more of the below options:

  • Find out if your partners, colleagues, and/or locations abroad can receive advance payments.
  • If you have a local partner organization in the host country, it is often simplest to work with them to manage your cash payments. Establish a service agreement with the partner organization, onboard them as a Penn supplier, disburse funds to the partner organization, and have them utilize those funds to manage local cash payments.
  • If you or another Penn colleague will travel to the location, request a travel advance prior to departure, for use in making small cash payments, in accordance with the Project/Program Advances Policy. Note that travel advance requests must be placed a minimum of 3 weeks prior to departure.
  • If you must carry cash abroad, be mindful not to carry excessive quantities of cash on your person, and plan ahead in the event of any emergencies.

If you are doing business in a foreign country, contact the Office of the Treasurer for assistance in operating bank accounts or making cross-border payments to foreign vendors.  Treasury oversees all university bank accounts, short-term investments, external financing, and the processing of incoming payments, including cash, check, electronic and credit card.

Heather Seitz
Director, Cash & Debt Management

+1 215.573.2635

It is against Penn policy for Penn employees to open bank accounts on behalf of Penn.

Doing business in a foreign country typically does not require a foreign bank account, as often payments may be handled through advance payments, online payments, or through a partner organization in the host country.

Anti-Corruption Laws

The University may be subject to numerous anti-bribery laws and regulations when conducting international activity both inside and outside the US. As Penn increases its global outreach and engagement, it increases its exposure to Global Anti-Bribery & Corruption Laws.  

If your activity takes you abroad, or if you are engaged in activity with foreign entities and individuals, you are responsible for adhering to US law and also any anti-bribery and corruptions laws that exist in the country in which you are operating. For example: 

Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act (FCPA) prohibits the offer, payment or promise of “anything of value” to a foreign official with the corrupt intent of obtaining or retaining business. This violation is not limited only to activities overseas, but also applies to actions taken in the U.S. that would further the corruption of a foreign official.

Learn more about the Foreign Corrupt Practices Act (FCPA) on our dedicated resource page:

International Operations

Key considerations and contacts for protecting data and IP rights, leasing space, and contracting with foreign entities.

International Agreements

Terms of an international agreement typically define the rights, responsibilities, and expectations of the involved parties. 

Crossing Borders

Crossing international borders involves more than just moving people; it also requires careful planning and compliance when transporting information, technology, and other critical supplies.

Research Guidelines & Regulations

The proposal process and operations procedures for global research must consider a range of factors beyond those associated with research conducted in the US.