Foreign Influence on University Research
Stony Brook University remains committed to the principles of academic freedom and
the open exchange of knowledge, which serve as the bedrock of research and scholarship.
Faculty and students are encouraged to participate in international collaborations.
However, such collaborations should be transparent and disclosed in a manner consistent
with applicable requirements, including those of federal and state agencies, as well
as Stony Brook’s own policies.
The Office of the Vice President for Research continues to monitor new regulations
and guidance provided by funding agencies regarding foreign collaborations, and we
will inform the University community of relevant changes. Updates and new information
will also be provided on this page.
Research activities that involve an international connection have come under increased
scrutiny from the U.S. Government. Universities, which have long considered the open
exchange of knowledge as an essential hallmark of research and scholarship, are now
the focus of attention in part because of these very freedoms. Federal funding agencies,
including National Institutes of Health (NIH), National Science Foundation (NSF),
Department of Energy (DoE), Department of Defense (DoD) and National Aeronautics
and Science Administration (NASA), have expressed serious concerns of inappropriate
influence from foreign sources over federally-sponsored research at universities and
other institutions in the US. These concerns arise partly from the potential for unauthorized
transfer of confidential information and intellectual property resulting from federally-funded
research to entities in other countries and the associated impacts to economic and
Federal funding agencies have provided guidance that reminds (and is some instances
expands) the research community of the requirements for disclosing foreign connections
relating to research activities, and have warned of possible consequences for failure
"Dear Colleague" letters
Revisions and additions to existing policy
Federal Agency Definitions
Definitions of the below terms may differ by sponsor as the federal agencies have
not adopted standard definitions or reporting requirements. Investigators must read
sponsor guidelines and requirements to ensure that they are disclosing and reporting
in accordance with the specified agency.
NOT-OD-19-114 ) defines a foreign component as:
The existence of any “significant scientific element or segment of a project” outside
of the United States, in other words:
1. performance of work by a researcher or recipient in a foreign location, whether
or not NIH grant funds are expended and/or
2. performance of work by a researcher in a foreign location employed or paid for
by a foreign organization, whether or not NIH grant funds are expended.
"Significant scientific element or segment of a project"
According to the
Activities that would meet this definition include, but are not limited to, (1) the
involvement of human subjects or animals, (2) extensive foreign travel by recipient
project staff for the purpose of data collection, surveying, sampling, and similar
activities, or (3) any activity of the recipient that may have an impact on U.S. foreign
policy through involvement in the affairs or environment of a foreign country. Examples
of other grant-related activities that may be significant are:
- collaborations with investigators at a foreign site anticipated to result in co-authorship;
- use of facilities or instrumentation at a foreign site; or
- receipt of financial support or resources from a foreign entity.
Foreign travel for consultation is not considered a foreign component.
Also known as "current and pending" or "active and pending" support.
NOT-OD-19-114) defines other support as:
All resources made available to a researcher in support of and/or related to all of their
research endeavors, regardless of whether or not they have monetary value and regardless
of whether they are based at the institution the researcher identifies for the current
grant. This includes resource and/or financial support from all foreign and domestic
entities, including but not limited to, financial support for laboratory personnel,
and provision of high-value materials that are not freely available (e.g., biologics,
chemical, model systems, technology, etc.).
Foreign Talent Program
Order 486.1) defines Foreign Talent Programs as:
Distinguishing features of a foreign government talent recruitment program covered
by this policy include:
(a) Compensation provided by the foreign state to the targeted individual in exchange
for the individual transferring knowledge and expertise to the foreign country. The
compensation can take several forms, such as cash, research funding, honorific titles,
career advancement opportunities, promised future compensation, or other types of
remuneration or other consideration.
(b) Recruitment refers to the foreign state sponsor's active engagement in attracting
the targeted individual to join the foreign-sponsored program and transfer their knowledge
and expertise to the foreign state. The targeted individual may be employed and located
in the United States, or in the foreign state.
Note that, generally, an invitation by a foreign state to simply attend or present
work at an international conference would not constitute recruitment.
At some institutions, failures to disclose foreign connections or other regulatory
violations have resulted in personnel actions and even indictments by law enforcement.
Some federal funding agencies have stated that investigators who fail to disclose
appointments or support from foreign entities may be ineligible to receive funding.
Transparency and Disclosure
Err on the side of transparency when considering or reporting a foreign activity
University Disclosure Requirements
Stony Brook University's Annual Disclosure Certification through the
myResearch portal requires reporting of positions and appointments at institutions other than
Stony Brook, whether paid or unpaid, as well as other support provided by entities
other than Stony Brook or Research Foundation for SUNY, whether monetary or non-monetary
Specific information on who must disclose and what needs to be disclosed as well as
frequently asked questions is available on the
Conflict of Interest and/or Commitment website.
Federal Funding Agency Disclosure Requirements
Investigators must pay careful attention to the sponsor’s guidelines.
Presently, there is no uniform practice among federal funding agencies for disclosing
international components of research activities. Furthermore, there exist multiple
ways in which such disclosures may be included in grant proposals and progress reports,
depending on the funding agency. In addition, funding
agencies provide guidelines for information to be included in publications resulting
from grants and contracts. They also generally require that all publications resulting
from sponsored research must be reported, typically in annual and final progress (or
Review current projects to ensure that all locations outside the U.S. where significant
scientific activities are performed (Foreign Components) have been disclosed through
progress reports and final technical reports.
Obtain prior approval when adding a Foreign Component to an existing federal award.
Include a clear description of all Foreign Components (as applicable) in all new proposals.
Review each funding application to ensure that all resources available in direct support
of an individual’s research activities (Other Support) is disclosed as required by
their federal sponsors.
- Determine if sponsor approval is required for international collaborations resulting
The following links are to assist investigators with complying with these requirements.
Cite in manuscripts only the funding which specifically supports the work in the publication.
Do not cite unrelated financial support in publications.
Funding agencies provide guidelines for information to be included in publications
resulting from grants and contracts. They also generally require that all publications
resulting from sponsored research must be reported, typically in annual and final
progress (or technical) reports. Researchers should carefully review the sponsor's
guidelines for reporting publications in reports as some sponsors differentiate between
publications where funding specifically supported the work in the publication and
all other publications.
Disclosure Guidance for Biosketches, Proposals and Reports
Individual faculty and staff of Stony Brook University are not permitted to complete
(i.e., sign) any agreement with a foreign entity.
|Type of Activity
||When to Seek Guidance
|Research collaboration with foreign entity or person
||Prior to the exchange of any information or deliverables under a scope of work
||Office of Sponsored Programs
|International academic partnership
||Prior to signing any Memorandum of Understanding (MOU) or other agreement
||Office of Global Affairs
|Memorandum of Understanding (MOU) for reasons other than international academic partnership
||Prior to exchange of any information or activities
||Office of Research Compliance
|Material Transfer Agreements (MTA)
||Prior to the exchange of any materials
||Office of Technology Licensing and Industry Relations
|Non-Disclosure Agreements (NDA) or Confidentiality Agreements (CDA)
||Prior to the exchange of any confidential information
||Office of Technology Licensing and Industry Relations
|Data Use Agreements
||Prior to the exchange of any data
||Office of Sponsored Programs and School of Medicine (see guidance
Members of the campus community traveling internationally using Research Foundation
funds are required to submit an
Electronic Foreign Travel Request
eFTR) prior to travel. Prior approval is required for travel to certain countries.
Members of the campus community inviting international visitors are reminded of the
SBU Guest/Visitor Policy P601.
U.S. export laws regulate the shipment, transfer, or disclosure of physical exports,
technical data, and software to foreign countries or to foreign persons, including
our students and faculty, and entities within the U.S. These laws aim to protect U.S.
national security, economic interests, and foreign policy. Moreover, these laws restrict
exports to certain entities and individuals, including some academic institutions
in some countries, as well as the sharing of technologies with individuals affiliated
with those entities while in the United States.
Faculty and staff who engage in the following activities should be aware of export
controls and how they apply in each case.
- Shipments to foreign locations
- Procurement of goods or services from foreign vendors
- Payments to foreign nationals and foreign companies
- Faculty and staff travel to foreign countries
- Contracting with a foreign source
- Hosting foreign visitors and delegations
- Foreign national access to controlled chemicals, microorganisms and toxins
- Research involving specific military applications
- Research collaboration with a third party appearing on a U.S. restricted party list
Specific information on export controls and how to comply is available on the
Export Compliance website.
Restricted Party Screening
Members of the campus community should consult Stony Brook’s
Export Control Policy (P212)
, which explains the requirement for a Restricted-Party Screening prior to engagement
with a foreign person or entity. A guidance document outlining best practices, responsible
parties, and access to software is available