Research Security FAQs

No

The federal government uses these terms to describe its concerns regarding nefarious actions by nation-states (or their representatives/agents) which could negatively impact the United States' economic competitiveness and national security.  The main areas of concern are: 

• Integrity of the peer review process 

• Undisclosed foreign resources, including but not limited to: foreign employment arrangements, foreign grant support that creates problems with overlap, or over-commitment, foreign talent programs 

• Undisclosed significant foreign financial conflicts of interest 

• Diversion of proprietary or pre-publication information disclosed in grant applications or produced by US-supported research to those not authorized to receive it (theft of intellectual property) 

• Compliance with regulatory requirements including US Export Control laws and regulations, which establish a set of requirements for the transfer of technology and data to foreign countries and/or foreign nationals in the US and sanctions from the Office of Foreign Assets Control, which restrict interactions with individuals or entities on the sanctions list 

As a result of these concerns, the federal government created new legislation and updated disclosure requirements to emphasize the importance for researchers and universities to disclose accurately, properly, and consistently and establish practices to reduce the risks. 

• Review information on this website
• Follow the best practices listed above 
• Ask questions, please refer to our 2RISE and ORA pages 
• Read campus communications regarding Research Security and International Engagement 

Failing to disclose all the required information such as foreign outside financial interests, relationships, and affiliations. Examples: 

• Not including the foreign country location of the organization/entity 

• Not disclosing participation in a foreign talents program as Other Support/Current & Pending Support to the federal agency. 

• Not disclosing receipt of foreign government grants or research funding. 

• Not disclosing position/appointment/time commitment at foreign institutions. 

• Having inconsistent information across the many disclosures collected for research proposals and awards, conflict of commitment, conflict of interest and other publicly available information (ex. publications). 

For example, disclosing activities in your Disclosure Profile (in the UDisclose System) but not including the income received from those activities in your other support disclosures for your NIH research proposal. 

Navigate to your Disclosure Profile within UDisclose. On the upper left-hand corner, the orange status box should read “No Action Required” if it has been successfully submitted.  

Below are some of the press releases and news articles related to the results of the federal government's investigations of university researchers: 

• Harvard University Professor and Two Chinese Nationals Charged in Three Separate China Related Cases (January 28, 2020) 

• Ex-Harvard professor sentenced to 6 months house arrest for lying about China ties (April 26 2023) 

• Researcher at University Arrested for Wire Fraud and Making False Statements About Affiliation with a Chinese University (February 27, 2020) 

• Former Emory University Professor and Chinese "Thousand Talents" Participant Convicted and Sentenced for Filing a False Tax Return (May 11, 2020) 

• NASA Researcher Arrested for False Statements and Wire Fraud in Relation to China's Talents Program: Texas A&M University Professor Working on U.S. Space Projects Allegedly Hid Affiliations with Chinese State-Owned Academic and Commercial Institution (August 24, 2020) 

• Legal win for US scientist bolsters others caught in China crackdown (November 17, 2022 

• Pall of Suspicion (March 23, 2023) 

• Stanford University Agrees to Pay $1.9 Million to Resolve Allegations That It Failed to Disclose Foreign Research Support in Federal Grant Proposals (October 2, 2023) 

A malign foreign talent recruitment program (MFTRP) refers to a recruitment initiative sponsored by a foreign country or entity that aims to attract science and technology professionals or students. These programs typically involve two key elements: 

1. Compensation: The foreign country or entity provides compensation to the researcher. This compensation can take various forms, including cash, in-kind contributions, research funding, travel opportunities, titles, or other non-de minimis benefits.
2. Specific Obligations or Activities: In exchange for the compensation, the targeted individual is required to engage in specific research activities, opportunities, or obligations. These activities may create risks such as conflicts of interest, conflicts of commitment, loss of intellectual property (IP), or other security concerns. 

Here are some important points related to MFTRPs: 

• Prohibition: Federally-funded researchers are prohibited from participating in MFTRPs. The CHIPS & Science Act of 2022 explicitly forbids such participation. MFTRPs must involve countries like China, Iran, North Korea, or Russia, or entities in those countries. Researchers will be required to certify that they are not involved in MFTRPs when applying for federal funding. 

• Disclosure: All federally funded researchers must disclose their participation in any foreign talent recruitment program (FTRP), whether malign or not. 

• Risk Assessment: During proposal evaluation, federal funding agencies may assess the risk associated with participation in certain FTRPs and may require mitigation measures before awarding funding. 

In summary, MFTRPs pose research security concerns, and federal regulations aim to prevent researchers from engaging in such programs to protect national interests and maintain research integrity.