Know Your Collaborator Guidance

Foreign Countries of Concern (FCOC) 

In the research security context, Foreign Countries of Concern (FCOCs) are countries designated by the U.S. government due to concerns about foreign influence, research security, and the potential misappropriation of federally funded research. Federal agencies—particularly the Department of Defense (DoD) and Department of Energy (DOE)—may apply heightened scrutiny to collaborations involving FCOCs. The current FCOC list includes China, Russia, Iran, and North Korea, although federal designations may change over time.

Collaborations with individuals affiliated with organizations such as the Chinese Academy of Sciences, or with entities appearing on federal restricted or prohibited lists, may prompt additional sponsor review and, in some cases, affect funding eligibility. This scrutiny can extend beyond the principal investigator to other senior/key personnel involved in the project.

• It is important to distinguish Foreign Countries of Concern (FCOCs) from the broader category of Countries of Concern, which may also include Venezuela and Cuba. Restrictions associated with Countries of Concern are often tied to export controls, sanctions, data and biospecimen transfers, or other regulatory requirements. As U.S. government designations evolve, additional countries or entities may be added to these lists

Disclosure requirements

The general rule: Foreign collaborators who are externally supported (by a foreign institution, hospital, or government entity) must be disclosed to your federal funding agency. Self-supported collaborators do not, generally, require disclosure unless they later obtain external support.

When in doubt, disclose. The Research Security & International Engagement team are available to review specific questions relating to disclosures and will discuss these questions with UM’s Office of Research Administration.

A few things to watch for: 

• If the objectives of a collaboration shift so that the collaborator becomes connected to your federal funding, disclosure may be required. 
• NSF disclosure requirements are broadly similar to NIH requirements. 
• DOW and DOE disclosure requirements are typically project-specific and may be stricter.

Restricted Party Screening

Restricted Party Screening (RPS) is the University of Miami's process for screening individuals, organizations, and institutions against U.S. government restricted, sanctioned, debarred, and prohibited-party lists. The goal is to ensure compliance with export control laws, sanctions programs, sponsor requirements, and research security obligations.

Screening is conducted for international collaborations, subrecipients, sponsors, vendors, visiting scholars, and other external partners. A potential match does not automatically prohibit the activity, but it may require additional review to assess compliance, research security, export control, or foreign influence risks.

RPS helps UM identify high-risk entities, comply with federal requirements, and protect federally funded research by ensuring collaborations and transactions can proceed legally and responsibly.

Learn more about When Should You Request a Restricted Party Screening and to request a Restricted Party Screening for current or prospective collaborators to help identify potential compliance risks and support informed, secure, and responsible research partnerships.

Managing international collaborations: Best practices

International Collaborations and Co-Authorship

International collaboration is essential to advancing research, innovation, and scholarly impact. The University of Miami supports open, transparent, and responsible engagement with researchers and institutions around the world. As research security requirements continue to evolve, researchers should consider disclosure, data protection, compliance, and research security considerations throughout the lifecycle of a collaboration.

The Research Security and International Engagement (RSIE) team is available to assist researchers in understanding and navigating research security considerations associated with international collaborations, co-authorship activities, and other foreign engagements.

Prior to initiating a new collaboration, consider:

• Who are the collaborators and what are their institutional affiliations?
• What are the goals, expectations, and anticipated outcomes of the collaboration?
• Will data, materials, software, technology, or equipment be shared?
• Does the project involve federally funded, sensitive, proprietary, or controlled research?
• Are there disclosure, export control, contractual, or other compliance requirements that may apply?
• Are all parties clear on authorship expectations, intellectual property considerations, and data-sharing responsibilities?

As collaborations evolve, periodically reassess the relationship and the activities being conducted.

Consider:

• Has the scope of the collaboration changed since it began?
• Have additional collaborators, institutions, students, or research personnel become involved?
• Are research data and materials being shared appropriately and securely?
• Have any new affiliations, appointments, funding sources, or outside commitments emerged?
• Are publication, data management, and intellectual property expectations being followed?
• Have any concerns arisen regarding transparency, disclosure, access to information, or other research security considerations?

Prior to submitting a manuscript, abstract, presentation, or other scholarly work, consider:

• Are all authors appropriately identified and affiliated?
• Are institutional affiliations accurate and complete?
• Have all required funding sources and acknowledgements been included?
• Have any sponsor disclosure requirements been satisfied?
• Does the publication contain confidential, proprietary, controlled, or otherwise restricted information?
• Are there any pending intellectual property, patent, or contractual considerations that should be addressed before public release?

Following publication, researchers should continue to monitor and manage collaborative relationships.

Consider:

• Do sponsor disclosures require updating?
• Have new research opportunities emerged from the collaboration?
• Are there ongoing obligations related to data retention, reporting, or compliance?
• Has the collaboration expanded into new research activities that may require additional review or guidance?

Confirm authorship, data ownership, and IP expectations early in the collaboration. Foreign collaborators should not take research data, unpublished manuscripts, or proprietary materials with them at the end of a collaboration without prior approval. Coordinate with the Office of Technology Transfer before embarking on research collaborations with the potential for inventions or patentable work.

Of note: the NIH recently clarified that many instances of foreign co-authorship may constitute a foreign component, requiring prior approval and/or prompt reporting to NIH. The agency has increased oversight of international collaborations and has been contacting institutions about publications that acknowledge NIH funding and include foreign co-authors, requesting additional information about the collaboration. The definition and examples can be found here.

Because some agencies use co-authorship as a proxy for collaboration, investigators should carefully assess whether foreign collaborations require disclosure or sponsor approval.

Researchers and trainees who leave UM to join a foreign institution should complete work on U.S.-funded projects before departure whenever possible. If they are later included on publications, NIH recently reminded investigators to list the affiliation where the NIH-funded work was performed (e.g., University of Miami), rather than a current foreign affiliation, when appropriate.

The NIH also reminded recipients that publications should acknowledge federal funding only when the grant directly supported the work being reported. In addition, some Notices of Funding Opportunity prohibit foreign components; where foreign components are not permitted, publications generally should not include foreign collaborators or co-authors associated with the funded work.

If you have questions about this notice or encounter challenges related to foreign components, please contact the Office of Research Administration or UM's Research Security Program at RSIE@miami.edu.

Some research areas, equipment, software, and technical data are subject to export control regulations under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). 

A deemed export can occur when controlled information is shared with a foreign national, even on U.S. soil. Contact exportcontrol@med.miami.edu before: 

• Sharing controlled technology 
• Providing access to controlled equipment 
• Shipping materials internationally 

If a foreign collaborator travels internationally during the collaboration, or if you travel to meet collaborators in an FCOC, follow institutional guidance on loaner devices, data handling, and travel registration. Do not carry sensitive research data on personal devices across borders.

Access additional guidance on the following:

• Protect Your Personal Information During Travel
• Foreign Travel Security

If something feels wrong, contact the Research Security & International Engagement team immediately.

External organizations or sponsoring entities sometimes pressure researchers or their foreign collaborators in ways that could compromise research integrity. Examples include requests for unauthorized data sharing, undisclosed affiliations, or participation in external programs that raise disclosure concerns. 

If you or a collaborator encounter pressure of this kind, or have concerns about coercion, surveillance, or unusual requests, contact RSIE@miami.edu or 305-243-6339. We can help identify mitigation strategies and, when appropriate, connect you with additional institutional or federal resources.

Casual correspondence generally does not qualify as a collaboration. A collaboration begins when there is shared work, exchange of unpublished data, joint authorship plans, or a time commitment. If you are unsure, ask RSIE@miami.edu.

Contact RSIE@miami.edu and your ORA Grants and Contracts Manager. A change in funding source can change disclosure obligations.

Request a Restricted Party Screening for the Individual and/or the institution against federal lists and assess any disclosure implications by sending the inquiry to RSIE@miami.edu.

Discuss this with your ORA Grants and Contracts Manager first. Under-disclosure can cost you an award; over-disclosure rarely costs anything.