Federal Focus on Inappropriate Foreign Influence on Research: Practical Considerations in Developing an Institutional Response

The document provides a comprehensive overview of the increasing federal focus on inappropriate foreign influence within U.S. research institutions and offers practical guidance for developing institutional responses to these emerging challenges. It highlights ongoing concerns related to the nondisclosure of foreign gifts, involvement in foreign government-sponsored talent programs, and the potential theft or diversion of intellectual property developed with U.S. government funding—risks that have prompted heightened scrutiny, particularly towards relationships with China. The federal response has included a variety of new and expanded legislative and agency requirements ranging from restrictions on specific foreign technologies to enhanced disclosure and reporting obligations for both researchers and institutions under executive directives such as NSPM-33 and guidance documents like the JCORE Guidance.

The paper advocates for a nuanced, risk-based approach to research security that balances the fundamental academic values of openness, collaboration, and knowledge dissemination with the necessity for increased vigilance and compliance. Key elements addressed include the management of conflicts of interest and commitment, enhanced monitoring and reporting of research activities and affiliations, cybersecurity and physical security measures, export controls compliance, and the protection of intellectual property and unpublished findings. The document emphasizes the importance of robust governance structures, including the potential establishment of dedicated research security units and interdepartmental communication, as well as ongoing education and training for researchers. It acknowledges the substantial cost implications for institutions—often unfunded by federal agencies—and the administrative burdens imposed. Ultimately, the document underscores that effective research security programs require a tailored, institution-specific risk assessment framework that enables compliance without undermining the openness and collaborative nature that are foundational to academic progress and innovation.