The university values diversity in thought, innovation, open scientific discourse and collaboration with the international research community. We understand that, for our international collaborations to be effective, they must be safe and free from malfeasance.

In response to a rising trend of our nation’s adversaries engaging in illicit activities and elicitation attempts, the United States government (USG) and sponsor agencies are implementing additional due diligence and risk management processes to safeguard international collaborations. These processes help researchers ensure our international collaborations do not present a risk to research data funded by the USG.

When considering international collaborations, personnel should understand their personal responsibilities. For more information, visit the Office of Research Compliance page on International Collaboration.

 

Due diligence and risk assessments

Covered individuals (see covered individuals definition in the right-hand column of this page) under the research security program shall contact the Office of Research Security (ORS) for assistance in conducting due diligence and risk assessments. This assessment is necessary if you are considering collaborating with individuals or entities from countries identified as foreign countries of concern by the USG (as defined in the CHIPS & Sciences Act of 2022 — currently China, Iran, North Korea and Russia), sanctioned/embargoed countries, as identified by the Office of Foreign Assets Control, or any other countries identified by individual federal agencies as being of concern. Assessment by the ORS is also necessary for collaborations involving export-controlled information, technology, items, software or services.

ORS must vet foreign individuals and entities with whom you are considering collaboration in advance of creating a collaborative relationship/agreement to ensure your work remains compliant with all export control, research security, USG or sponsor agency restrictions or requirements. The ORS does not act as an approval authority but does serve as your resource for information to assist you in decision making, proposal development and risk mitigation.

U.S. federal funding agencies are currently developing risk matrices for each of their organizations. As these matrices are finalized, they will be the primary tools funding agencies use to gauge risk in research collaborations. The ORS will place final funding agency risk matrices on this site as they become available. For now, this site is currently tracking evolving criterion for the agencies releasing this information.

While there are differences in how each agency determines risk, they are all concerned about the following factors, especially if they involve a foreign country of concern or sanctioned country:

• Undisclosed support
• Undisclosed affiliations
• Participation in foreign talent recruitment programs, especially those identified as malign
• International research collaborations involving STEM, critical emerging technologies, or military dual-use applications
   

 

Malign foreign talent recruitment programs

Covered individuals must report if they are a party to a foreign talent recruitment program contract, agreement or other arrangement. The university prohibits employees from participating in such programs. Failing to disclose these affiliations can result in criminal or civil liability.

To safeguard against recruitment into a malign foreign talent program:

• Refer to the following research policy for additional information: RSCH 1.10 Prohibition on Participation in Malign Foreign Talent Recruitment Programs (pdf).
• Refer to the ORS’s 1-2-3 graphic guidance to determine if you may be involved in a malign foreign talent recruitment program.
• Contact the ORS with your questions or for further guidance.

 

Export Control

Certain information, technology, software, items or services may be subject to U.S. export control regulations such as the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), and Department of Energy 10 CFR Part 810 and NRC 10 CFR Part 110.

Currently the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has comprehensive sanctions for Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk and Luhansk regions of Ukraine. OFAC maintains a real-time list of Sanctions Programs and Country Information on its website. If your foreign collaboration involves an export-controlled component, an OFAC-sanctioned/embargoed country or there is uncertainty, individuals are required to contact the USC Export Control Empowered Official for additional guidance before collaboration.