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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 centralized 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 advice and recommendations to university leadership. Contact GERP Director Jessa Albertson at jalbertson@stanford.edu for more information.

Resources

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

NSF: Dear Colleague Letter: A Request for Input on the Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization. May 4, 2023

Office of Science and Technology Policy Subcommittee on Research Security: Draft Research Security Programs Standard Requirement. February 2023

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

National Counterintelligence and Security Center (NCSC) Safeguarding Science

Dept. of Energy: Office of Science Laboratory Policy, Science and Security 

NIH: Foreign Interference 

NSF: Research Security 

DARPA: Countering Foreign Influence Policy

Stanford Guidance: Contact with law enforcement 

NIHNSFDOEDoDOther

Foreign Interference 

 

NSF: Research Security 

Dear Colleague Letter: A Request for Input on the Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization. May 4, 2023

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 Policy Subcommittee on Research Security: Draft Research Security Programs Standard Requirement. February 2023

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. While not prohibited if the participant complies with all applicable regulations, requirements and policies, participating in a FGTRP sponsored by China, Russia, Iran and North Korea can preclude an individual from receiving certain types of federal funding.  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).

Identifying Foreign Government Talent Recruitment Programs "FGTRP"

The following have been identified by DOD as, "Foreign Talent Programs that Pose a Threat to National Security Interests of the United States". Participating in one of these programs after August 9, 2024 is a "prohibited factor" per DOD, and will limit DOD funding.

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

 

From, National Security Presidential Memorandum (NSPM-33) Presidential Memorandum on United States Government-Supported Research and Development National Security Policy

  • Sec.2.(e) the term “foreign government-sponsored talent recruitment program” or “foreign government-sponsored talent recruitment programs” means an effort directly or indirectly organized, managed, or funded by a foreign government or institution to recruit S&T professionals or students (regardless of citizenship or national origin, and whether having a full-time or part-time position).  Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government.  Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose.  Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities.  Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation. 
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"

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

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.

 

 

 

Participating in a FGTRP may prevent you from receiving federal funding. Participation should always be approved in writing by your School Dean, disclosed to Stanford and federal funding agencies. 

 

 

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

Check your sponsor’s current disclosure requirements carefully: if in doubt, disclose

 

Disclosures to Stanford

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

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

    • Barbara L. Flynn, Director of the School of Medicine Conflict of Interest Review Program.

 

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,

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

    • Glennia Campbell, Director, Industrial Contracts Office.

 

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

Created: 03.02.21
Updated: 07.26.23