The document outlines the Department of Defense's (DoD) comprehensive policy for risk-based security reviews of fundamental research, particularly as conducted by academic institutions. In the context of maintaining U.S. dominance in science and technology, the DoD recognizes the critical value of open science and international collaboration, but balances this with emerging national security concerns. The policy, responding to directives in the National Security Presidential Memorandum-33 (NSPM-33) and related legislative mandates, establishes that all fundamental research proposals selected for funding undergo a thorough risk-based security review. This review aims to identify and, where possible, mitigate potential risks linked to foreign influence, such as participation in malign foreign talent recruitment programs, undisclosed affiliations or funding from entities of concern, and improper handling of intellectual property.
The policy mandates a transparent, consistent, and non-discriminatory process across DoD components, supported by a decision matrix that systematizes the assessment of potential conflicts of interest and commitment. Mitigation, rather than rejection, is the preferred approach to managing risks, with examples including enhanced reporting, required training, or personnel reassignment. Proposals are denied only if risks cannot be effectively mitigated or if required by law, with clear justification and avenues for institutional appeal. Oversight is maintained by the Office of the Under Secretary of Defense for Research and Engineering (OUSD(R&E)), which conducts spot checks and ensures policy alignment across agencies. The policy is further supported by published lists of foreign institutions and talent programs identified as security risks (in accordance with relevant legislation), and DoD commitments to ongoing engagement with the academic community to refine policy measures as needed.
