Countries of Concern
Overview
Certain countries receive additional scrutiny under federal research security policies, export control regulations, federal sponsor requirements, and other U.S. government programs. Research involving these countries is not prohibited solely because of the country involved; however, additional institutional review, sponsor requirements, or regulatory requirements may apply depending on the activity.
The Office of Research Security (ORS) assists faculty, staff, and students in identifying applicable requirements before international research activities begin.
What is a Country of Concern?
The term Country of Concern is used in different ways by different federal agencies and programs.
Depending on the context, it may refer to countries identified through:
- Federal research security policies
- Federal sponsor requirements
- Export control regulations
- U.S. sanctions programs
- Other federal laws or executive actions
Because these definitions vary, ORS evaluates international activities using the applicable requirements for the proposed research activity.
Current Countries of Concern
For research security purposes, ORS generally reviews activities involving:
- China (including Hong Kong)
- Iran
- North Korea
- Russia
Additional countries or regions may require review depending on sponsor requirements, export control regulations, sanctions programs, or other federal requirements.
Activities That May Require Additional Review
Activities involving a Country of Concern may require additional review before they begin.
Examples include:
- International research collaborations
- Foreign-sponsored research
- International visitors
- International travel
- International data sharing
- International research agreements
- International shipments
- Sharing technology, software, or unpublished research information
Why Additional Review May Be Needed
Depending on the activity, ORS may evaluate:
- Federal sponsor requirements
- Export control requirements
- Research security considerations
- Research cybersecurity requirements
- Restricted entity screening
- Sanctions and embargoes
- International agreements
- Other institutional requirements
Countries of Concern vs. Sanctioned Countries
| Countries of Concern | Sanctioned Countries |
|---|---|
| Research security concept | Legal restrictions |
| Additional review may be required | Activities may be prohibited or require authorization |
| Often depends on sponsor or institutional requirements | Governed primarily by U.S. sanctions regulations |
A country may be a Country of Concern without being comprehensively sanctioned, and a sanctioned country is subject to separate legal restrictions under U.S. law.
Frequently Asked Questions
Does collaborating with a researcher in a Country of Concern automatically prohibit the collaboration?
No. Many collaborations may proceed after appropriate institutional review and compliance with applicable sponsor, export control, and other requirements.
Do all federal sponsors use the same definition?
No. Federal agencies may implement research security requirements differently.
Should I contact ORS before establishing a collaboration?
Yes.