International Research and Engagement

What is Research Security?

Research Security is protecting the means, know-how, and products of research until they are ready to be shared, by approval of the leader(s) of the research program and other stakeholders in their security.

—JSR-22-08, JASON. 2023. " Research Program on Research Security".

Related Information

• Watch UCOP’s Research Security: Video Shorts
• Foreign Talent Recruitment Program (FTRP)
• Malign Foreign Talent Recruitment Program
• UC policy on the prohibition of Malign Foreign Talent Recruitment Program (MFTRP)

Questions contact: RCIResearchSecurity@ucsd.edu

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• Conflict of Commitment (COC): The University of California requires that faculty submit an annual COC report indicating whether or not they have engaged in outside activities during the fiscal year. Disclosure forms are required even if faculty members have nothing to disclose. Deans are responsible for ensuring that faculty members submit an annual disclosure and that the disclosures are accurate. A UC-wide software system called UC OATS is now being used for annual COC disclosures. Read more on the Academic Affairs UC OATS website. 
• Conflict of Interest (COI) policies require all university employees who are conducting research or other research-related activities to disclose certain financial interests, whether domestic or foreign. Financial interests include anything of monetary value held by the employee, a spouse or registered domestic partner, and dependent children. Examples include income or payments for salaries; consulting or honorariums; holding a position such as founder, partner, employee or board member; and having ownership interests such as stocks, bonds or stock options. New financial interests should be disclosed within 30 days of their acquisition. Read more about required COI disclosures here.
• Applicants for federal grants must list all “other support” prior to award as required by the sponsoring agency and are required to identify any changes in “other support” in each annual progress report. For NIH awards, the NIH Grants Policy Statement defines “other support” as all financial resources — whether federal or non-federal, commercial or institutional — in direct support of an individual’s research. This covers research contracts and grants, cooperative agreements and organizational awards, including any from foreign governments or entities. Contact the Office of Contract and Grant Administration for more information about the “other support” requirements of your sponsor.

It is important to remember that any external support or engagement that would be acknowledged in public presentations or publications is something that should also disclosed in grant applications, annual reports and closeout summaries and in university-related COI and COC disclosure forms (as required).

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Defense Advanced Research Projects Agency (DARPA)

• December 1, 2021:  Risk-Based Measures to Assess Potential Undue Foreign Influence Conflicts of Interests or Conflicts of Commitments
• December 1, 2021:  Countering Foreign Influence Program (CFIP) Frequently Asked Questions

Department of Commerce

• May 21, 2019: DOC's Bureau of Industry and Security adds Huawei Technologies Co., Ltd. and its subsidiaries to the Entity List, subjecting them to Export Administration Regulations.

Department of Defense (DOD)

• June 29, 2023: Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education
• October 10, 2019: DOD Under Secretary Michael D. Griffin sends letter to research community "outlining the current rising tensions and fears of potential espionage, intellectual property theft, and threats to academic integrity posed by foreign powers."
• March 20, 2019: DOD Under Secretary Michael D. Griffin issues memo titled "Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies." The memo details the DOD requirements for disclosures on the sources of support for principal investigators and other key personnel.

Department of Energy (DOE)

• Frequently Asked Questions (FAQs)
• September 4, 2020: DOE issues a memo on foreign government sponsored or affiliated activities.
• June 7, 2019: DOE issues a directive that prohibits DOE and DOE contractor personnel from participating in talent recruitment programs operated by certain foreign countries.
• January 31, 2019: DOE issues a memo restricting funded researchers from participating in foreign talent recruitment programs.
• December 14, 2018: DOE issues a memo on collaborating with colleagues from "sensitive" countries on "emerging research areas and technologies."

National Aeronautics and Space Administration (NASA)

• February 9, 2012: NASA Restrictions on Funding activities with the People’s Republic of China (NASA Grant Information Circular GIC 12-01).

National Defense Authorization Act

• August 2018: Sec.1286 states that “The Secretary of Defense shall, in consultation with other appropriate government organizations, establish an initiative to work with academic institutions who perform defense research and engineering activities . . . to limit undue influence, including through foreign talent programs, by countries to exploit United States.

National Institutes of Health (NIH)

• May 22, 2023: NIH Foreign Interference: General Principles, Case Studies, Publicly Available Information on Special Cases, and Oversight Reports.
• July 30, 2021: Foreign Interference in National Institutes of Health Funding and Grant Making Processes: A Summary of Findings From 2016 to 2021
• April 28, 2021: NOT-OD-021-110 Implementation of Changes to the Biographical Sketch and Other Support Format Page
• NIH Frequently Asked Questions – Other Support and Foreign Components
• Protecting U.S. Biomedical Intellectual Innovation (includes requirements for disclosure of other support, foreign relationships and activities, and conflicts of interest)
• March 12, 2021: NOT-OD-21-073 Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021
• July 10, 2019: NIH issues a reminder of "NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components." 
• August 23, 2018: NIH Director Francis S. Collins issues a statement on protecting U.S. biomedical research and national security interests.
• March 30, 2018: NIH issues a notice reminding the research community of the obligation to disclose foreign financial interests.

• January 30, 2023:  NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support 
  Previous versions:
  • April 20, 2022
  • January 10, 2022 
  • September 1, 2021 
  • August 24, 2021
  • June 16, 2021

• April 20, 2022: Frequently Asked Questions on Current and Pending Support

  Previous versions:

  • June 28, 2021
• May 2020: NSF Approved Formats for Biographical Sketch (NEW requirements starting October 5, 2020) 
• October 31, 2022: NSF Proposal & Award Policies & Procedures
• July 11, 2019: NSF Director Frances Cordova issues a letter to the research community on the importance of addressing "emerging risks to the nation's science and engineering enterprise."

National Science and Technology Council (NSTC)

• January 2022:  NSTC Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33).  

Office of Science and Technology Policy (OSTP)

• This Memo discusses the issue of foreign influences on research and describes steps OSTP is taking to address these threats.

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• Export Control
  • Overview
  • Restricted Party Screenings 
  • Researcher Guidance on Export Control 
  • International Shipping Regulations 
• Cybersecurity 
• Accurately reporting international activities in grant applications and university disclosures:
  • University of California policy on Conflict of Commitment and Outside Activities of Faculty Members for general campus faculty. Academic Personnel Manual (APM), Section 025.
  • Conflict of Commitment and Outside Activities of Health Sciences Compensation Plan Participants for faculty participating in the Health Sciences Compensation Plan. Academic Personnel Manual (APM), Section 671.
    • APM 671 Frequently Asked Questions (FAQs) (Log-in required)
  • Conflict of Interest Office 
  • Office of Contract and Grants International Research Collaboration
  • University of California Office of the President (UCOP) Foreign Influence Guide
• Signing unfunded agreements (e.g., MOUs) with foreign institutions or organizations
• Sponsoring visiting scholars and researchers
• Visa sponsorship and invitations to UC San Diego for students and scholars
• Travel Abroad
  • What to know before traveling outside the U.S. (PDF) 
  • International shipments and hand-carrying equipment or materials abroad 
  • International travel cybersecurity 
  • UC San Diego Travel 
  • If you need to obtain a visa to travel to a foreign country, please contact that country’s consulate office. You can also find information on the U.S. State Department’s travel website. 
  • Travel to sanctioned or embargoed countries may have restrictions or require a license from the U.S. government. Some other destinations are considered high-risk, and we recommend you follow guidance from the U.S. State Department.
  • University faculty and staff routinely host international colleagues for short-term visits to campus. In rare cases, visiting scholars may be pressured by their home countries to inappropriately access information or research facilities and equipment. If you are asked by a visiting scholar to facilitate the visit of a foreign delegation or asked to sign a Memorandum of Understanding with a foreign institution, please contact the Office of Postdoctoral and Research Scholars Affairs.

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Frequently Asked Questions

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The UC Office of the President has a comprehensive resource on foreign influence with more background information and links to the relevant UC system policies. There may be additional guidance in the future as foreign talent programs evolve. 

For additional information or assistance, please contact the Research Compliance and Integrity Office at rci@ucsd.edu or (858) 822-4939.

References

Department of Energy Directive O 486.1A, Foreign Government Sponsored or Affiliated Activities

Federal Bureau of Investigation Public Service Announcement

National Science Foundation 19-200 Dear Colleague Letter: Research Protection

Research Security Video Series

PowerPoint presentation (PDF) and one-sheet handouts from May 2019 international research town halls.

• Export Control
• Graduate Division
• International Travel
• Conflict of Interest and Conflict of Commitment
• Conflict of Interest--PHS-Funded Researchers
• Office of Contract and Grant Administration
• Office of Innovation and Commercialization
• Office of International Affairs
• Office of Postdocs and Research Scholars

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