Foreign Influence

Florida State University is committed to facilitating open and publicly accessible research and scholarly activities, both domestically and internationally. With growing concerns from U.S. federal sponsors for agreements and activities with various foreign institutions, the Office of Research Integrity, Security, and Ethics is available to provide guidance and assist you in navigating the everchanging regulations related to international relationships.

Foreign Talent Recruitment Programs

Malign Foreign Talent Recruitment Programs (MFTRP)

FSU's Policy on Foreign Talent Recruitment Programs

FAQ - Frequently Asked Questions

Contact

Foreign Influence Training

Foreign Talent Recruitment Programs

What is a foreign talent recruitment program?

Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue. (Office of Science and Technology Policy)

More generally, a foreign talent recruitment program is an effort organized, managed, or funded by a foreign government, or a foreign government entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). (National Institute of Standards and Technology)

The below international collaboration activities typically are NOT considered foreign talent recruitment programs:

1. Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law;
2. Participating in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law; and
3. Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student's request.

Malign Foreign Talent Recruitment Programs (MFTRP)

What is a malign foreign talent recruitment program (MFTRP)?

1. Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual— 
   1. 1. engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;
      2. being required to recruit trainees or researchers to enroll in such program, position, or activity;
      3. establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;
      4. being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
      5. through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;
      6. being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;
      7. being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;
      8. being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or
      9. having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; AND
2. A program that is sponsored by—
   1. 1. a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern;
      2. an academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232); or
      3. a foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232).”  (CHIPS & Science Act)

Please note: A foreign country of concern is defined as the People’s Republic of China, the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the Venezuelan regime of Nicolas Maduro, the Syrian Arab Republic, or any other country determined to be a country of concern by the U.S. Department of State. (§ 288.860 F.S., CHIPS & Science Act, FSU Policy 7A-39)

FSU's Policy on Foreign Talent Recruitment Programs

The Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act of 2022 prohibits federal employees, contractors, and awardees – including institutions, individual investigators, and other key personnel – from participating in Malign Foreign Talent Recruitment Programs.

At Florida State University, covered individuals are prohibited from participating in a federally funded research and development project if they are currently participating in a malign foreign talent recruitment program, and must disclose if they are a party to any other foreign talent recruitment program. 

Each covered individual must certify annually, or more frequently if required, compliance with this policy.

A covered individual is defined as an individual who contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; AND is designated as a covered individual by the Federal research agency concerned. (CHIPS & Science Act)

Florida State University uses the Conflict Administration Management System (CAMS) to complete the annual certification of compliance with the Malign Foreign Talent Recruitment Program Participation policy. See the CAMS Project website for more information.

Frequently Asked Questions

Q1: What are the specific concerns regarding “foreign influence” in research?

A1: Federal government agencies have expressed concern that some foreign actors, particularly foreign state adversaries, are seeking to acquire U.S. academic research and information illicitly or illegitimately in order to advance their scientific, economic, and military development goals through the exploitation of the culture of collaboration and openness on university campuses.

Q2: I have been invited to participate in a foreign talent recruitment program. What should I do?

A2: You should not proceed or agree to participate until you have discussed this situation with RISE. RISE keeps up to date on developments in federal guidelines and regulations around foreign talent recruitment programs, as well as the University Administration’s position on this matter.

Q3: I will have future travel sponsored by a foreign government. Do I need to disclose this?

A3: Yes, all international travel must be booked in Concur, whether or not the University is paying for the travel or another source is providing support. The Office of Compliance and Ethics reviews international travel submissions in Concur and performs necessary screenings and follow up. Disclosures may also be required in proposals to funding agencies, so review agency proposal submission guidelines closely.

Q4: A foreign entity has asked me to be a consultant on a project they are working on. Do I need pre-approval?

A4: Yes, if you offered a consultant appointment, you should request pre-approval via your CAMS disclosure profile. You should also consult with RISE on conflict of interest and export control concerns. Disclosures may also be required in proposals to funding agencies, so review agency proposal submission guidelines closely.

Q5: I frequently work with foreign collaborators on my federally-funded research. Do I have to disclose these collaborations?

A5: Yes, federal funding agencies have specific clauses that may limit international collaboration. Contact RISE prior to starting any international collaboration related to the research or otherwise. Disclosures may also be required in proposals to funding agencies, so review agency proposal submission guidelines closely.

Q6: I have an ownership interest in a foreign company. Do I have to disclose this?

A6: Yes, you should disclose this interest on your Outside Activity Report. You should also consult with RISE on conflict of interest and export control concerns, and the Office of Commercialization for intellectual property issues. Disclosures may also be required in proposals to funding agencies, so review agency proposal submission guidelines closely.

Q7: I want to host a foreign visiting scholar to work in my lab for the summer. What do I need to do to accomplish this?

A7: Please follow FSU’s policy and procedures concerning inviting a visiting scholar. This information can be found at https://fda.fsu.edu/faculty-employment/appointments/procedures-for-inviting-an-unpaid-visiting-scholar-researcher. 

Q8: I have an unpaid researcher or student working in my lab. How should I disclose this? 

A8: Scholars, researchers and students working in your lab with direct support from any organization other than FSU (including those who identify as “self-funded”) must be listed on your Other Support or Current & Pending Support Documents (the label differs between sponsors).  While the format or template of each of these documents e may differ, they generally require the following information.  Suggested guidance for each field is below:

1. Project Number: If applicable, include a code or identifier for the work.
2. Source of Support: Identify the entity that is providing the support for the researcher to be at FSU. This may be their home institution, their home government, a non-profit foundation, or self-funded.
3. Major Goals: Provide a brief statement of the program or projects on which they are working.
4. Dates of Approved/Proposed Project: Indicate the inclusive dates of the time frame in which they will be working in your lab.
5. Annual Direct Costs: Estimate an annual value of the time to your lab. For example, a student supported by their home country would be valued at the same rate as a University supported GA salary + fringe + tuition.
6. Percent Effort/Person Months: As you are not required to provide any additional effort for oversight as allowable under presidential memorandum M-01-06, you may report 0 effort months.

Foreign Influence Training

RISE is pleased to provide faculty, staff, and students an online self-paced course focused on research integrity and foreign influence. This course will give an overview of FSU policies and guidance from various authorities regarding the risk of foreign influence on research, as well as helping to identify where additional information can be located on FSU’s websites.

Course Registration:

You can self-enroll in this training by using the following instructions:

1. Open this link, and then proceed to Step 2.
2. Once the link has opened, sign in with your FSU credentials (if prompted).
3. Once signed in click the “Enroll in Course” button. You’ll then be registered in the course.
4. Launch the online training module by clicking the Modules tab, and then selecting the “Research Integrity” course under Course Presentation.

Please note: The above training does not satisfy the Research Security Training requirements. Please navigate to CITI Program to complete Research Security Training. 

Contact

Anyone with questions about foreign influence or international research should contact the Office of Research Integrity, Security, and Ethics, research-compliance@fsu.edu.