Foreign Engagement

The U.S. Government, including the federal agencies that fund much of MIT’s research, has expressed serious concerns regarding inappropriate influence by foreign entities, government, or individuals on U.S. institutions and researchers. Key concerns of the U.S. Government regarding undue foreign influence are:

• failure of researchers to disclose support from outside activities or foreign organizations in federal grant applications that may overlap with grant scope or over-commit researchers;
• sharing of confidential information by researchers serving as peer reviewers of federal grant applications;
• undisclosed significant financial conflicts of interest;
• misappropriation or unlawful transfer of U.S. intellectual property, data, or unpublished research results;
• unlawful transfer of research materials and samples;
• presence of agreements with foreign entities that may impose obligations on researchers that are contrary to university policies or federal grant requirements; and
• data security and cyberattack vulnerability.

Several federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding.

Concerns about undue foreign influence have been exacerbated by the inappropriate and intentional actions of a few. Undue foreign influence concerns can be mitigated by informing researchers of institutional and federal disclosure requirements and best practices to prevent inadvertent or premature sharing of sensitive research data to foreign entities.

MIT uses the CITI Program for the training needs of faculty, researchers, students and staff. CITI has developed a four-part course titled Undue Foreign Influence: Risks and Mitigations which covers the following:

• Undue Foreign Influence Impacts and Concerns for Academia
• Reporting, Research Integrity, and Effective Practices to Manage Undue Foreign Influence Risk
• Cybersecurity and Compliance Considerations for Safeguarding Research
• Nondiscrimination Considerations When Managing Undue Foreign Influence

Anyone who is involved in research at MIT is encouraged to complete this course.  Each module can be completed in approximately 30 minutes or less.

Use the links below for:

• Instructions to set up your account (first time users) 
• Instructions to add new courses to your existing profile 

Go to CITI Program Training

(Valid MIT certificate required.)

In compliance with individual sponsor requirements, certain collaborations and/or affiliations with foreign as well as domestic entities or individuals must be disclosed in proposals and reports. Such collaborations may include exchanges of staff, materials, data, funding, or other significant activity which could result in joint authorship.

Failure to fully disclose foreign/domestic collaborations, affiliations, and resources in funding applications and other documents can have serious consequences, and may endanger MIT’s eligibility for future federal funding.

When an MIT Principal Investigator submits a proposal to the Kuali Coeus system for final review by MIT Research Administration Services (RAS) and further submission to a federal agency, the PI is certifying that all information is complete and accurate to the best of his or her knowledge, and failure to disclose may lead to charges of providing fraudulent information. In some cases, failure to disclose has led to criminal charges against individual researchers.

Additional information on recent actions taken by various government agencies against researchers who have not fully disclosed their foreign support and affiliations can be found in this July 7, 2020 article in Nature, this July 15, 2020 article in Chemistry World, and this November 27, 2020 article in Bloomberg Law.

Please contact the appropriate sponsor liaison or contract administrator in RAS if you have any questions on disclosure requirements. The policies of the various agencies are not consistent and are being continuously modified. The disclosure policies of some key agencies are summarized below:

• Department of Defense
• Department of Energy
• National Aeronautics and Space Administration
• National Institutes of Health
• National Science Foundation

For disclosure policies of other federal research sponsors, please review the program announcements and proposal preparation guides, and contact your RAS contract administrator with any questions.

Portions of the contents of this section were adapted from materials prepared by UCLA Research Policy and Compliance and are provided here with their permission.

This chart summarizes the financial conflict of interest (fCOI) and outside professional activities (OPA) policies under which faculty members, other investigators and staff must disclose certain information to MIT in order to achieve compliance with federal, state, and Institute requirements. Additional details and links to policy are provided following the chart.

Please note that the fCOI and OPA disclosure processes at MIT do not replace sponsor-specific disclosure requirements, especially for federal sponsors. Review all sponsor-specific proposal and award information, or speak to your contact in Research Administration Services to ensure you have disclosed all required information to meet sponsor requirements.

Financial Conflicts of Interest

Financial Conflicts of Interest must be identified and either managed or eliminated. Disclosure of Significant Financial Interests is an integral part of this process.

Significant Financial Interest means a financial interest that meets any of the criteria for significance set forth below and is received or held:

1. by an Investigator; or
2. by an Investigator and members of his or her Family; or
3. solely by members of the Investigator’s Family, but only if the financial interest could reasonably appear to be related to the Investigator's Institutional Responsibilities,

A financial interest is deemed to be significant if:

1. the aggregate value of Remuneration and Equity Interests in lieu of payment received from a US or foreign publicly traded entity during the 12-month period preceding the disclosure exceeds $5,000; or
2. the aggregate value of Equity Interests in a US or foreign publicly traded entity exceeds $5,000 and the entity is sponsoring any of the Investigator’s research; or
3. the aggregate value of Equity Interests in a US or foreign publicly traded entity exceeds $100,000 and the entity’s business, or any portion thereof, reasonably appears to be related to any of the Investigator’s Institutional Responsibilities; or
4. the aggregate value of Remuneration received from a US or foreign non-publicly traded entity or non-profit institution received during the 12-month period preceding the disclosure exceeds $5,000; or
5. any Equity Interest is held in a US or foreign non-publicly traded entity; or
6. the aggregate value of Remuneration received from a foreign governmental organization during the 12-month period preceding the disclosure exceeds $5,000; or
7. the aggregate value of income related to intellectual property rights and interests paid by an entity other than MIT exceeds $5,000.

Significant Financial Interest does NOT include:

1. Remuneration from MIT; (including salary and royalty payments) and
2. Remuneration paid to an Investigator’s Family by any entity what would not reasonably appear to be related to the Investigator’s Institutional Responsibilities; and
3. Remuneration from authorship of academic or scholarly works, regardless of the source; and
4. Remuneration from seminars, lectures, or teaching engagements sponsored by, or from advisory committees or review panels for, U.S. Federal, state, or local governmental agencies; U.S. institutes of higher education (e.g. Whitehead Institute and Broad Institute); U.S. research institutes affiliated with institutes of higher education, academic teaching hospitals, and medical centers; and
5. Equity Interests in or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions for these vehicles.

Forms, policies and procedures, and other guidance can be found on the VPR Financial Conflicts of Interest in Research website.

Outside Professional Activities

The Institute’s policies governing outside professional activities are designed to encourage active participation in research enriched in many cases by interaction with industry, business, government, and other activities and institutions.

• Information for MIT Faculty regarding Outside Professional Activities is available in MIT’s Policies and Procedures §4.5. Department heads and center/laboratory directors counsel faculty and researchers regarding specific cases. The Faculty Policy Committee recommends appropriate modifications of policies and procedures to the Faculty.
• Non-faculty research staff are subject to specific rules concerning outside professional activities depending on their position at the Institute and detailed in Policies and Procedures §2.0, §5.0, and §6.0 for each appointment type. A summary of normally conferred consulting privileges for various positions at MIT can be found on the VPR Outside Professional Activities page.

Reports of outside professional activities (whether compensated or uncompensated) must include all foreign and domestic activities. Outside professional activities must be reported and updated during the annual OPA reporting cycle which starts in May of each year, via the MIT Outside Professional Activities (OPA) portal.

Portions of the contents of this page were adapted from materials prepared by UCLA Research Policy and Compliance and are provided here with their permission.

Updated June 8, 2022

The International Coordinating Committee (ICC) [website] supports the MIT community in planning, negotiating and implementing international activities.  As of May 2022, a new MIT Global Support Resources (GSR) website was launched, bringing together the essential administrative resources from across MIT to assist members of the community in planning and managing their global activities. This site is provided by the Office of the Associate Provost, International Activities in collaboration with the ICC.

International proposals in the following categories require additional “elevated risk” review by the ICC and the MIT Senior Risk Group:

• projects funded by people or entities from China (including Hong Kong), Russia and Saudi Arabia;
• projects which involve MIT faculty, staff or students conducting work in these countries;
• and collaborative projects with people or entities from these countries. 

Issues considered in the elevated risk process include: US economic competitiveness; US national security; political, civil and human rights; potential impacts on the MIT community, consistency with MIT’s core values, and alignment with MIT’s academic mission; and risk related to intellectual property, export control compliance, and data security and access.  As international circumstances change, the list of countries or activities subject to this additional review may be modified.

A full description of the elevated risk process can be found at GSR's "Elevated-risk project review process" webpage.

Make sure that you and your staff complete all necessary Export Control Training and that you check the Export Control website for current updates. Remember, exports refer not only to physical items, but also to intangibles such as ideas and information.

As stated above, the unlawful transfer of research materials and samples is a significant concern of the U.S. Government; items such as biologicals, chemicals, batteries and fuel cells, or radioactive materials may be restricted or have specific licensing requirements. The Export Control page on Biological, Hazardous, or Radioactive Material provides links to current guidance regarding shipping such items. When in doubt, contact the Export Control Office for further guidance.

Review MIT’s Intellectual Property Policy and promptly disclose inventions and proprietary information to via Technology Licensing Office IP Forms [website].

For an overview of current Federal regulations for working with non-U.S. collaborators and sponsors see our Regulations for Non-U.S. Activity page.

Informal collaborations, where there is no written agreement or exchange of funds, can still leave MIT researchers vulnerable to legal or financial penalties.  Researchers (including staff, postdocs, and graduate students) should report informal collaborations in the Informal International Collaborations (IIC) tool. The VPR Compliance team will review each submitted collaboration and contact the researcher with any questions or concerns.

October 2019

• DOD letter to universities and research centers describing their efforts to protect the integrity of the U.S. research enterprise and asking for support in doing so.

March 2019

• Memorandum clarifying information to be provided for senior/key personnel as part of a proposal and that the information would be used for purposes including protection of intellectual property and limiting undue influence.

June 2019

• DOE Order 486.1 provides further guidance to employees and contractors regarding talent recruitment programs.

January 2019

• Memorandum that contains policy prohibiting DOE personnel from participating in foreign talent recruitment programs.

NASA has been restricted by statute since 2011 from using NASA funds to enter into agreements “to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement” (grant restrictions, contract restrictions).

October 2020

• NIH gave a presentation entitled "Commitment Transparency" at its Virtual Seminar on Program Funding and Grants Administration. During this presentation, NIH advised that it would soon be issuing a notice that provides clarifications to researcher disclosure obligations for Biosketches and Other Support. Among the anticipated new requirements is that institutions must provide NIH with copies of contracts that researchers have with foreign entities. The new requirements are expected to take effect in early 2021.

July 2020

• Protecting U.S. Biomedical Intellectual Innovation is a page under “Policy and Compliance” on the NIH Grants and Funding website which summarizes current guidance and links to current policy documents.

July 2019

• Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components and accompanying FAQs on Other Support and Foreign Components.
• The NIH’s Advisory Committee to the Director Working Group on Foreign Influences on Research Integrity continues to work to address concerns.

August 2018

• Dr. Francis Collins issued a letter to grantees and published a Statement on Protecting the Integrity of U.S. Biomedical Research. In these documents, NIH highlighted the following areas of concern:
• Diversion of intellectual property in grant applications or produced by NIH-supported biomedical research to other entities, including other countries;
• Sharing of confidential information by peer reviewers with others, including with foreign entities, or otherwise attempting to influence funding decisions; and
• Failure by some researchers at NIH-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds.

Since 1978, NSF has required senior project personnel on proposals to disclose all sources of support, both foreign and domestic.

• Protecting Research and Facilitating Collaboration is a web page created and maintained by NSF, which provides information about their communications and actions regarding safeguarding research while fostering open research and collaboration. Please refer to this page for the most up-to-date communications.

October 2020

• NSF-Approved Formats for Current and Pending Support. As of October 5, 2020, NSF requires that information on all current and pending support for ongoing projects and proposals be submitted using an NSF-approved format.

June 2020

• Enhancing the Security and Integrity of America’s Research Enterprise provides an overview with examples and case studies illustrating concerns of the U.S. Government.

September 2019

• Letter to the United States Research Community from Director of the Office of Science and Technology Policy emphasizing the importance of protecting the integrity of our nation’s research enterprise.