The university values diversity in thought, innovation, open scientific discourse and collaboration with the international research community. We understand that, for our international collaborations to be effective, they must be safe and free from malfeasance.
In response to a rising trend of our nation’s adversaries engaging in illicit activities and elicitation attempts, the United States government (USG) and sponsor agencies are implementing additional due diligence and risk management processes to safeguard international collaborations. These processes help researchers ensure our international collaborations do not present a risk to research data funded by the USG.
When considering international collaborations, personnel should understand their personal responsibilities. For more information, visit the Office of Research Compliance page on International Collaboration.
Due diligence and risk assessments
Covered individuals (see covered individuals definition in the right-hand column of this page) under the research security program shall contact the Office of Research Security (ORS) for assistance in conducting due diligence and risk assessments. This assessment is necessary if you are considering collaborating with individuals or entities from countries identified as foreign countries of concern by the USG (as defined in the CHIPS & Sciences Act of 2022 — currently China, Iran, North Korea and Russia), sanctioned/embargoed countries, as identified by the Office of Foreign Assets Control, or any other countries identified by individual federal agencies as being of concern. Assessment by the ORS is also necessary for collaborations involving export-controlled information, technology, items, software or services.
ORS must vet foreign individuals and entities with whom you are considering collaboration in advance of creating a collaborative relationship/agreement to ensure your work remains compliant with all export control, research security, USG or sponsor agency restrictions or requirements. The ORS does not act as an approval authority but does serve as your resource for information to assist you in decision making, proposal development and risk mitigation.
U.S. federal funding agencies are currently developing foreign affiliation risk matrices for each of their organizations. As these matrices are finalized, they will be the primary tools funding agencies use to gauge risk in research collaborations. Currently, the agencies below are using the five risk assessment criteria shown heading the columns in the risk assessment matrix below. Although the full impact of these risk assessments on future funding and award considerations is not clearly defined, researchers should be aware of and consider the potential impacts. As additional agencies release criteria, we will add them to this page.
While there are differences in how each agency determines risk, they are all concerned about the following factors, especially if they involve a foreign country of concern or sanctioned country:
- Undisclosed support
- Undisclosed affiliations
- Participation in foreign talent recruitment programs, especially those identified as malign
- International research collaborations involving STEM, critical emerging technologies, or military dual-use applications
How federal agencies assess specific risks
The below expandable lists indicate how each listed agency considers a set of five specific risks, and provides relevant notes and resources to aid in understanding:
- Participation in a foreign talent recruitment program
- Direct funding from a Country of Concern
- Foreign patents filed in foreign Countries of Concern
- Affiliations and appointments
- Co-authorship with persons affiliated with institutions in Countries of Concern
Participation in a foreign talent recruitment program
The DoD considers this a risk if the program is associated with a Country of Concern or if it is not disclosed.
Direct funding from a Country of Concern
Yes, the DoD considers this a risk.
Foreign patents filed in foreign Countries of Concern
Yes, the DoD considers this a risk.
Affiliations and appointments
The DoD considers this a risk if it occurred wthin the past 5 years, and the affiliation is with an Entity of Concern and there are indicators of non-disclosure of the affiliation/appointment.
Co-authorship with persons affiliated with institutions in Countries of Concern
The DoD considers this a risk if it occurred within the past 5 years and if the co-author is affiliated with an Entity of Concern.
DoD research security resources
Participation in a foreign talent recruitment program
The U.S. Army considers this a risk if the program is associated with Country of Concern or if it is not disclosed.
Direct funding from a Country of Concern
Yes, the U.S. Army considers this a risk.
Foreign patents filed in foreign Countries of Concern
Yes, the U.S. Army considers this a risk.
Affiliations and appointments
The U.S. Army considers this a risk if it occurred wthin the past 5 years, and the affiliation is with an Country of Concern and there are indicators of non-disclosure of the affiliation/appointment.
Co-authorship with persons affiliated with institutions in Countries of Concern
The U.S. Army considers this a risk if it occurred within the past 5 years and if the co-author is affiliated with an insitution in a Country of Concern.
U.S. Army notes and resources
- The U.S. Army’s program has significant differences from the general DOD program, so it is broken out separately in this matrix.
- U.S. Army Research Risk Assessment Protection Program website
- U.S. Army Risk Protection Program FAQs (pdf).
Participation in a foreign talent recruitment program
The DOE and NNSA consider this a risk if the program is associated with a Country of Concern or if it is not disclosed.
Direct funding from a Country of Concern
Yes, the DOE and NNSA consider this a risk.
Foreign patents filed in foreign Countries of Concern
Yes, the DOE and NNSA consider this a risk.
Affiliations and appointments
The DOE and NNSA consider this a risk if it occurred wthin the past 5 years, and the affiliation is with an Entity of Concern and there are indicators of non-disclosure of the affiliation/appointment.
If an affiliation is identified in the past 5 years, DOE may ask for a signed assurance from the investigator that the affiliation is no longer active.
Co-authorship with persons affiliated with institutions in Countries of Concern
This risk is not applicable to the DOE and NNSA.
DOE research security resources
Participation in a foreign talent recruitment program
The NIH considers this a risk if the program is associated with a Country of Concern or if it is not disclosed.
Direct funding from a Country of Concern
The NIH considers this a risk if it is not disclosed. Most agencies consider January 2022, the date the NSPM -33 Implementation guidance was published with the expected disclosure requirements as the date investigators should have been aware of these requirements. Indicators of non-disclosure after that date will likely result in a higher identified risk.
Foreign patents filed in foreign Countries of Concern
This risk is not applicable to the NIH.
Affiliations and appointments
The NIH considers this a risk if it occurred wthin the past 5 years, and the affiliation is with an Entity of Concern and there are indicators of non-disclosure of the affiliation/appointment.
Co-authorship with persons affiliated with institutions in Countries of Concern
This risk is not applicable to the NIH.
NIH research security resources
Participation in a foreign talent recruitment program
The NSF considers this a risk if the program is a malign foreign talent recruitment program or if it is not disclosed.
Direct funding from a Country of Concern
The NSF considers this a risk if it is not disclosed. Most agencies consider January 2022, the date the NSPM -33 Implementation guidance was published with the expected disclosure requirements as the date investigators should have been aware of these requirements. Indicators of non-disclosure after that date will likely result in a higher identified risk.
Foreign patents filed in foreign Countries of Concern
This risk is not applicable to the NSF.
Affiliations and appointments
The NSF considers this a risk if the affiliation or appointment is active, and it is with an Entity of Concern and there are indicators of non-disclosure of the affiliation/appointment.
Co-authorship with persons affiliated with institutions in Countries of Concern
This risk is not applicable to the NSF.
NSF notes and resources
- The NSF is implementing its research security program, TRUST (Trusted Research Using Safeguards and Transparency), in phases. Phase I began Fiscal Year 2025 (October 1, 2024) and is focused on quantum related research. Read more in the NSF TRUST Policy Memo (pdf).
- NSF Research Security web page
It remains to be determined how the DHS will consider the five risks addressed in this matrix.
Participation in malign foreign talent recruitment programs
For all agencies, the more recent the participation in foreign talent recruitment programs identified as malign or associated with foreign Countries of Concern, the higher the identified risk. Active participation in a malign foreign talent recruitment program is prohibited by all federal funding agencies.
Entities of concern
An entity of concern is defined as any entity that the US Government has identified in accordance with Section 10114 of the CHIPS Act of 2022 (Public Law 117-167) as posing an unmanageable threat to the national security of the United States or of theft or loss of United States intellectual property. Please contact the ORS to conduct restricted party screening on all foreign entities you are considering affiliation or collaboration with.
Malign foreign talent recruitment programs
Covered individuals must report if they are a party to a foreign talent recruitment program contract, agreement or other arrangement. The university prohibits employees from participating in such programs. Failing to disclose these affiliations can result in criminal or civil liability.
To safeguard against recruitment into a malign foreign talent program:
- Refer to the following research policy for additional information: RSCH 1.10 Prohibition on Participation in Malign Foreign Talent Recruitment Programs (pdf).
- Refer to the ORS’s 1-2-3 graphic guidance to determine if you may be involved in a malign foreign talent recruitment program.
- Contact the ORS with your questions or for further guidance.
Export Control
Certain information, technology, software, items or services may be subject to U.S. export control regulations such as the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), and Department of Energy 10 CFR Part 810 and NRC 10 CFR Part 110.
Currently the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has comprehensive sanctions for Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk and Luhansk regions of Ukraine. OFAC maintains a real-time list of Sanctions Programs and Country Information on its website. If your foreign collaboration involves an export-controlled component, an OFAC-sanctioned/embargoed country or there is uncertainty, individuals are required to contact the USC Export Control Empowered Official for additional guidance before collaboration.