Academic Integrity and Undue Foreign Interference

Introduction Federal agencies that support research, federal intelligence agencies, federal security agencies, and Members of Congress have all expressed concern about systematic programs of foreign interference at U.S. research universities. In light of these concerns, federal agencies that support research are reviewing their policies and strengthening their attention to disclosure. The Association of American Universities (AAU) has urged all U.S. universities to do the same. Stanford joins the AAU in our commitment to national security, economic prosperity, openness in research, freedom of expression, the free exchange of scholarly ideas and fundamental research, and principled international collaboration.  Statement from President Marc Tessier-Lavigne and Provost Persis Drell on Foreign Engagement and Support for University Researchers February, 8, 2023

Global Engagement Review Program

GERP is a voluntary advisory process created to evaluate potential undue foreign influence risks in the context of maintaining our open and welcoming community. The program coordinates input from multiple offices that advise on various aspects of foreign engagements to assess risks related to undue foreign influence, research security and integrity.

Faculty or administrators may recommend or request GERP review by contacting the GERP Director. When an engagement presents an elevated risk, the director will work with the GERP Staff Committee of subject matter experts to assess risk and develop recommendations that support academic and research goals. On rare occasions the GERP Staff Committee may determine that the risks associated with an engagement are exceptionally high. When this happens, the GERP Staff Committee will refer the matter to the GERP Faculty Committee who will review the engagement and provide guidance and recommendations to the faculty or staff member requesting review. Contact GERP Director Jessa Albertson at jalbertson@stanford.edu for more information.

Resources

OSTP Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs. February 14, 2024

NSF Research Security Training.  January 2024

DOD: Department of Defense Strengthening Efforts to Counter Unwanted Foreign Influence on DOD-Funded Research at Institutions of Higher Education. June 30, 2023

DOD: Letter to the academic community regarding risks related to improper foreign interference. October 10, 2019

DARPA: Countering Foreign Influence Policy

Stanford Guidance: Contact with law enforcement 

NIH	NSF	DOE	DoD	Other
Foreign Interference  NIH Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel. August 15, 2024	NSF: Research Security	Memo outlining DOE's approach to Research, Technology, and Economic Security (RTES) risk.  November, 2024 Office of Science Laboratory Policy, Science and Security	Countering Unwanted Foreign Influence at Institutions of Higher Education June 29, 2023 Letter to the academic community regarding risks related to improper foreign interference. October 10, 2019	Office of Science and Technology's Policy Guidelines for Research Security Programs July 9,2024 National Counterintelligence and Security Center (NCSC) Safeguarding Science

Guidance regarding Foreign Government Talent Recruitment Programs "FGTRPs"

FGTRPs are programs sponsored by foreign governments to recruit faculty, researchers or students to support the sponsoring county’s interests. Sponsors may include national, regional or local governments as well as non-U.S. universities. Many governments sponsor FGTRPs for legitimate and mutually beneficial purposes. However, some FGTRPs may require or incentivize activities that are contrary to regulations, policies, and core research values. The U.S. government has expressed serious concerns about FGTRPs sponsored by the governments of China, Russia, Iran and North Korea and covered individuals participating in "Malign Foreign Government Talent Recruitment Programs" are prohibited from participating in federally funded research and development. Participation in these programs should always be approved by your School Dean, disclosed to Stanford and federal funding agencies.

Restriction on Malign Foreign Government Talent Recruitment Programs

The CHIPS and Science Act of 2022 (Public Law 117-167) requires federal research agencies to establish policies requiring covered individuals to certify that they are not a member of a malign foreign talent recruitment program at proposal submission and annually thereafter for the duration of the award.

The CHIPS and Science Act defines "Malign Foreign Government Talent Recruitment Programs" as:

A. Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual—

(i) engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country, or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;

(ii) being required to recruit trainees or researchers to enroll in such program, position, or activity;

(iii) establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;

(iv) being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;

(v) through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;

(vi) being required to apply for and successfully receive funding from the sponsoring foreign government’s funding agencies with the sponsoring foreign organization as the recipient;

(vii) being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;

(viii) being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or

(ix) having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; and

B) a program that is sponsored by—

i) A foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern; Currently China, North Korea, Russia, Iran

ii) An academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 2358 note; Public Law 115-232); or 

iii) A foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 2358 note; Public Law 115-232). Both lists can be found in DOD's Countering Unwanted Foreign Influence policy. 

Identifying Foreign Government Talent Recruitment Programs "FGTRP"

A foreign talent recruitment program is defined as any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.

The following activity is not considered a FGTRP

1. Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law;
2. Participating in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law;
3. Advising a foreign student enrolled at an institution of higher education or writing a
   recommendation for such a student, at such student's request; and
4. Engaging in the following international activities:
   1. Activities that are partly sponsored or otherwise supported by the United States such as serving as a government appointee to the board of a joint scientific fund (e.g., the U.S.-Israel Binational Industrial Research and Development Foundation); providing advice to or otherwise participating in international technical  organizations, multilateral scientific organizations, and standards setting bodies (e.g., the International Telecommunications Union, Intergovernmental Panel on Climate Change, etc.); participating in a Fulbright Commission program funded in whole or in part by a host country government; or other routine international scientific exchanges and interactions such as providing invited lectures or participating in international peer review panels.
   2. Involvement in national or international academies or professional societies that produce publications in the open scientific literature that are not in conflict with the interests of the federal research agency (e.g., membership in the Pontifical Academy of Sciences or The Royal Society).
   3. Taking a sabbatical, serving as a visiting scholar, or engaging in continuing education activities such as receiving a doctorate or professional certification at an institution of higher education (e.g., the University of Oxford, McGill University) that are not in conflict with the interests of the federal research agency.
   4. Receiving awards for research and development which serve to enhance the prestige of the federal research agency (e.g., the Nobel Prize)
   5. Other international activities determined appropriate by the federal research agency head or designee

Examples of FGTRPs  

The following have been identified by DOD as, "Foreign Talent Programs that Pose a Threat to National Security Interests of the United States". These programs are considered Malign Foreign Government Talent Recruitment Programs. Covered personnel in federally funded research are prohibited from participating in these programs. 

1. Changjiang Scholar Distinguished Professorship

2. Hundred Talents Plan

3. Pearl River Talent Program

4. Project 5-100

5. River Talents Plan

7. Thousand Talents Plan

Note: "Malign" talent programs are not limited to the programs listed above. Review the definition of Malign Foreign Government Talent Recruitment Programs closely. 

Georgetown University’s Center for Security and Emerging Technology “CSET” Chinese Talent Program Tracker provides a non-exhaustive list of programs. You can review the list here.

 

 

 

 

 

Disclosure

Disclosure to Sponsors

If you have questions about preparing sponsored research documents, visit the Office of Research Administration's online disclosure resources or SoM Research Management Group's online disclosure resources. You may also contact:

• Russell Brewer, Associate Vice President, Office of Research Administration, or
• Kathleen Thompson, Director, SoM's Research Management Group

 

Disclosures to Stanford

• If you have questions about disclosure of your outside activities, contact:

  • Ronda Anderson, Director, Conflict of Interest and Conflict of Commitment

     

 

Export Control

• When collaborating with international partners, making financial transactions, shipping materials, transferring technology, traveling abroad, or using restricted materials for research, comply with US export control regulations.
• If you have questions about export control,
  • consult the Export Controls Decision Tree or
  • contact the Export Control Office.

Intellectual Property

• Sign and adhere to Stanford’s SU-18 and SU-18a agreements. In particular, disclose to Stanford all potentially patentable inventions conceived or first reduced to practice in whole or in part in the course of your University responsibilities or with more than incidental use of University resources. Remind your group members and collaborators to do the same.
• If you are a director or an affiliated researcher of an Industrial Affiliates or related membership-supported program, review the policies, principles, and procedures for the establishment and operation of such programs.
• If you have questions about intellectual property, industrial contracts, or affiliates programs, contact:

  • Karin Immergluck, Director, Office of Technology Licensing, or

     

 

News

2023

NPR: Congress tightens U.S. manufacturing rules after battery technology ends up in China - January 30, 2023

DOJ. Castro Valley Resident Pleads Guilty To Illegally Exporting American Aviation Technology To Beijing University - January 17, 2023

 

2022

National Academies of Sciences, Engineering, and Medicine 2022. Protecting U.S. Technological Advantage - 2022

MIT: University Engagement with China: An MIT Approach - November, 2022

WSJ. U.S.-China Tensions Fuel Outflow of Chinese Scientists From U.S. Universities - September 22, 2022

NYT. Russian Scientists Face Isolation Following Invasion of Ukraine - March 12, 2022

NSF Pre-award and Post-award Disclosures Table - updated January 10, 2022

Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33). This document provides guidance to Federal departments and agencies for implementing NSPM-33 on National Security Strategy for U.S. Government-Supported Research and Development - January 4, 2022

2021

Clear Rules for Research Security and Researcher Responsibility, Statement from Dr. Eric Lander, President Biden's Science Advisor and Director of the Office of Science and Technology Policy (OSTP) - August 10, 2021

NIH Foreign Interference Summary of Findings, Background information and summary of compliance reviews and findings from Dr. Mike Lauer, Deputy Director for Extramural Research at NIH - July 2021

NIH Frequently Asked Questions (FAQs) Other Support and Foreign Components, New and Updated FAQs

A Renewed U.S. Commitment to International Education, Joint Statement from U.S. Departments of State and Education - July 2021

Recommended Practices for Strengthening the Security and Integrity of America's Science and Technology Research Enterprise, Report from the National Science and Technology Council Joint Committee on the Research Environment (JCORE) - January 19, 2021

2020

NIH Protecting U.S. Biomedical Intellectual Innovation, NIH and the biomedical research enterprise have a long history of International collaborations with rules of engagement that allow science to advance while also protecting intellectual capital and proprietary information of the participating countries. These rules of engagement also are designed to limit bias in the design, conduct, and reporting of NIH-supported research. This page describes actions that NIH, institutions, and researchers can take to protect U.S. biomedical intellectual innovation. The principles described here align with those announced by the White House's Office and Science and Technology Policy in June 2020.

U.S. Senators’ Letter to American Hospital Association, emphasizing disclosure requirements to NIH and seeking information about foreign influence measures taken by institutions - January 22, 2020

Science article on Moffitt Cancer Center resignations as a result of failures to disclose foreign relationships, January  19, 2020, and publicly released report of an internal investigation - January 17, 2020

-  Science Magazine Article

- Report of Investigation

2019

Science and Security Concerts Continue to Grow, NIH - December 16, 2019

NIH Other Support and Foreign Components FAQ - August 6, 2019

NSF Director, Dr. France Córdova, Dear Colleague Letter on Research Protection - July 11, 2019

NIH, Office of the Director, Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114) - July 10, 2019

NIH Advisory Group to the Director, Working Group on Foreign Influences on Research Integrity Update - June 19, 2019

NSF Response to Senator Charles Grassley's Letter  - April 26, 2019

Survey by AAU and APLU of Actions Taken by Universities to Address Growing Concerns about Security Threats and Undue Foreign Influence on Campus – April 22, 2019.

Letter from Senator Charles Grassley to the Director of the National Science Foundation - April 15, 2019

Memo from the Under Secretary of Defense on Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel, and Critical Technologies - March 20, 2019

New DOE policies would block many foreign research collaborations, Science Magazine – February 8, 2019

2018

Foreign Influences on Research Integrity - 117th Meeting of the Advisory Committee to the Director of the NIH -  December 13, 2108

Statement by the Association of American Universities - October 23, 2018

Foreign Influence Letter to Grantees - Dr Francis Collins, Director, NIH -August 20, 2018

The FY19 National Defense Authorization Act includes a provision alluding to the restriction of federal funding to institutions doing business with certain Chinese telecommunications companies - August 13, 2018

NIH Notice NOT-OD-18-160 Financial Conflict of Interest: Investigator Disclosures of Foreign Financial Interests - March 30, 2018

2017

DOE P 485.1, Foreign Engagements with DOE National Laboratories –  DOE Office of Science - January 19, 2017