In July 2023, the Department of Defense (DOD) released a suite of materials establishing new requirements and processes to identify and mitigate risks associated with unwanted foreign influence, conflicts of interest, and conflicts of commitment in DOD-funded fundamental research at higher education institutions. In support of National Security Presidential Memorandum-33 and relevant federal statutes, these materials—including a comprehensive Under Secretary memorandum, a Decision Matrix, and publicly available entity lists—direct DOD components to implement systematic, risk-based security reviews of research proposals and ongoing projects. These reviews focus on identifying connections to foreign talent recruitment programs, problematic foreign funding sources, and associations with foreign entities of concern. The Decision Matrix categorizes risk factors, prescribing specific mitigation or prohibitive actions for certain behaviors, particularly those that become riskier if occurring after key dates. The entity lists flag specific foreign institutions and talent programs considered threats to U.S. national security interests.
Funded institutions must ensure that researchers disclose relevant information and comply with strict prohibitions, such as barring participation in malign foreign talent recruitment programs and, in most cases, associations with Confucius Institutes. The guidance calls for consistent processes across DOD components, use of standardized risk assessment tools, and periodic review and reporting to DOD leadership. Institutions must train faculty on these requirements and navigate a complex landscape of permissible and prohibited activities, with significant implications for eligibility to receive DOD funding. The new framework aims to enhance research integrity and safeguard U.S. research assets while balancing the need to continue international collaboration where appropriate.
