This document outlines the increasing federal scrutiny on inappropriate foreign influence in U.S. academic research and offers practical considerations for institutions to develop effective research security responses. Triggered by concerns such as undisclosed foreign funding, participation in foreign government talent programs, and intellectual property theft—especially with a focus on China—U.S. government agencies have implemented stricter regulatory and compliance requirements for research recipients. Noteworthy measures include prohibitions on certain foreign technology vendors, enhanced gift and contract reporting, expanded disclosure obligations for affiliations and funding, and new federal guidance (notably through NSPM-33 and JCORE) that emphasize risk-based security programs and increased institutional oversight.
The paper advocates for a balanced, risk-based approach: recognizing the necessity of international scientific collaboration and open dissemination while assessing and mitigating risks unique to each institution’s research profile. Key operational areas discussed include managing conflicts of interest and commitment, robust reporting and monitoring of research outcomes, export controls, cybersecurity, the management of international visitors and students, and the protection of intellectual property. The importance of institutional governance structures for cross-functional coordination is highlighted, as is the need for comprehensive training, transparency, and ongoing risk assessment. The document also flags significant cost and administrative burdens associated with these federal mandates, with concerns that such requirements amount to unfunded mandates for research institutions. Ultimately, the document underscores the imperative for academic institutions to harmonize compliance with federal guidelines while upholding core academic values of openness, collaboration, and knowledge dissemination.
