Foreign Talent Recruitment Programs
Policy on Malign Foreign Talent Recruitment Programs & Foreign Talent Recruitment Programs
POLICY ON INTERNATIONAL ENGAGEMENTS
Overview
Federal research agencies require institutions and investigators to disclose certain foreign appointments, affiliations, research support, and other professional activities that may constitute participation in a Foreign Talent Recruitment Program (FTRP). In addition, individuals participating in federally funded research are prohibited from participating in a Malign Foreign Talent Recruitment Program (MFTRP) under federal law and sponsor requirements.
Participation in a Foreign Talent Recruitment Program is not automatically prohibited. Many legitimate international research collaborations, academic appointments, scholarly exchanges, and professional activities do not constitute an FTRP or are specifically excluded under federal guidance.
The Office of Research Security (ORS) assists faculty, staff, and students in evaluating foreign appointments, affiliations, research support, compensation, and other international activities to determine whether disclosure or additional review may be required.
Foreign Talent Recruitment Programs
The Office of Science and Technology Policy (OSTP) has established a government-wide definition of a Foreign Talent Recruitment Program (FTRP) for use by federal research agencies.
In general, an FTRP is a foreign-sponsored program, position, or activity that provides compensation or other benefits—including research funding, salary, travel support, laboratory resources, honorific titles, career advancement opportunities, or other remuneration—in connection with research or professional activities.
Participation in an FTRP is not prohibited. However, depending on the circumstances, participation may require:
- Disclosure to the University;
- Disclosure to federal sponsors;
- Sponsor certifications;
- Institutional review; or
- Additional sponsor approvals.
Researchers should consult ORS whenever they are uncertain whether a foreign appointment, affiliation, funding arrangement, or professional activity may constitute an FTRP.
Malign Foreign Talent Recruitment Programs
The CHIPS and Science Act established restrictions on participation in Malign Foreign Talent Recruitment Programs (MFTRPs).
Federal sponsors generally prohibit covered individuals participating in federally funded research from participating in an MFTRP.
Although each situation must be evaluated individually, an MFTRP generally involves a foreign-sponsored arrangement that requires an individual to:
- Transfer nonpublic research information or intellectual property;
- Conceal participation from a federal sponsor or employing institution;
- Establish undisclosed foreign laboratories or appointments;
- Recruit researchers into prohibited programs;
- Duplicate federally funded research;
- Violate award terms and conditions; or
- Create conflicts of interest or conflicts of commitment contrary to sponsor requirements.
Whether a particular activity constitutes an MFTRP depends on the specific facts, contractual obligations, sponsoring organization, and applicable federal requirements.
Activities That May Require Review
Researchers should contact ORS before they:
- Accept a faculty appointment, adjunct appointment, or visiting scholar position with a foreign institution.
- Accept research funding or other support from a foreign government, university, company, or research organization.
- Receive salary, honoraria, laboratory space, research funding, travel support, or other compensation from a foreign entity.
- Enter into agreements establishing foreign research appointments or affiliations.
- Participate in a foreign talent recruitment program.
- Recruit researchers or students on behalf of a foreign organization.
- Participate in federally sponsored research while maintaining significant foreign appointments or affiliations.
- Are uncertain whether a proposed activity may constitute an FTRP or MFTRP.
Activities Generally Not Considered Foreign Talent Recruitment Programs
Federal guidance recognizes that many routine international academic and scholarly activities are not considered Foreign Talent Recruitment Programs.
Examples include:
- Publishing research in the open scientific literature.
- Presenting research at scientific meetings and conferences.
- Participating in international research collaborations involving the open exchange of scientific information.
- Advising international students.
- Serving on international scientific organizations or standards-setting bodies.
- Participating in Fulbright and similar exchange programs.
- Membership in professional societies or national academies.
- Receiving internationally recognized research awards.
- Serving as a visiting scholar or taking a sabbatical that does not conflict with federal award requirements.
Whether an activity qualifies for one of these exclusions depends on the specific facts and applicable federal guidance.
Federal Sponsor Requirements
Many federal sponsors now require investigators to:
- Certify that they are not participating in an MFTRP.
- Disclose foreign appointments and affiliations.
- Report foreign research support.
- Complete Common Forms and sponsor disclosure documents.
- Update disclosures throughout the lifecycle of a sponsored project.
Although sponsor requirements vary, these disclosures support transparency, research integrity, and research security.
Researchers should review sponsor-specific disclosure requirements before proposal submission and throughout the life of an award.
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Research Security
Foreign Talent Recruitment Programs are one component of the federal research security framework established under NSPM-33, the CHIPS and Science Act, and related federal guidance.
Researchers considering foreign appointments, affiliations, research support, or other international professional activities should also consider whether the proposed activity involves a Foreign Country of Concern, a foreign government, or an organization that may require additional institutional review or sponsor disclosure.
Activities involving organizations located in—or affiliated with—a Foreign Country of Concern may require additional review because of federal research security requirements, sponsor policies, export controls, or other institutional requirements.
ORS assists researchers in identifying applicable disclosure requirements, sponsor expectations, and other research security-related considerations before accepting foreign appointments or participating in international activities.
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University Disclosure Requirements
Participation in an FTRP—or activities that may constitute an FTRP— require disclosure through the University's Disclosure of External Interests & Commitments program.
Maintaining an accurate University Disclosure Profile helps ensure institutional and sponsor disclosures remain complete, accurate, current, and consistent.
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Frequently Asked Questions
What is a Foreign Talent Recruitment Program?
A Foreign Talent Recruitment Program (FTRP) is defined by the Office of Science and Technology Policy (OSTP). In general, it involves a foreign-sponsored program, position, or activity that provides compensation or other benefits in connection with research or professional activities. Participation is not automatically prohibited but may require disclosure or institutional review.
What is a Malign Foreign Talent Recruitment Program?
An MFTRP is a subset of Foreign Talent Recruitment Programs prohibited under federal law for covered individuals participating in federally funded research. These programs generally involve activities that create conflicts with U.S. research security requirements, sponsor obligations, or institutional responsibilities.
Are all foreign appointments prohibited?
No. Many foreign academic appointments, visiting scholar positions, international collaborations, and professional activities are permissible. However, some appointments may require disclosure or additional review before they are accepted.
Do I have to disclose participation in an FTRP?
Yes. University policy and federal sponsor requirements may require disclosure of foreign appointments, affiliations, research support, compensation, or other activities.
What should I do if I receive an invitation from a foreign institution?
Before accepting a foreign appointment, affiliation, compensation, research support, or other professional activity, contact ORS for guidance. Early review helps identify any applicable disclosure, sponsor, or research security requirements.
Need Assistance?
If you are considering a foreign appointment, affiliation, research support, compensation arrangement, or other international professional activity and are uncertain whether it may constitute a Foreign Talent Recruitment Program or require disclosure, contact the Office of Research Security before accepting the activity.
Early consultation helps ensure compliance with University policy, sponsor requirements, and federal research security expectations while supporting responsible international research and collaboration.
