Malign Foreign Talent Recruitment Programs (MFTRPs)

Malign foreign talent recruitment programs attempt to unethically or unlawfully acquire U.S. scientific-funded research or technology. Members of the MIT community must contact MIT Research Compliance (research-compliance-help@mit.edu) if contacted by these programs, and follow sponsor requirements to certify that they are not participating in these programs.

Recognizing Malign Foreign Talent Recruitment Programs

Many countries sponsor talent recruitment programs for legitimate purposes. These programs may offer research fellowships and grants to incentivize researchers to physically relocate.

However, some programs encourage or direct unethical and criminal behaviors. "Malign foreign talent recruitment" programs include any foreign-state-sponsored attempt to unethically or unlawfully acquire U.S. scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States. Learn more about assessing and mitigating the risks posed by malign foreign talent recruitment programs. 

Guidelines issued by the federal government define malign foreign talent recruitment programs, as well as foreign talent recruitment programs generally.

  • The U.S. government currently regards all foreign talent recruitment programs sponsored by the governments of or organizations in China, Iran, North Korea, and Russia to be malign in nature. However, a malign foreign talent recruitment program can be based in any country.

  • A malign foreign talent recruitment program does at least one of the following: 

    • Requires unauthorized transfer of IP, materials, data products or other nonpublic information to a foreign government or entity
    • Requires recruitment of trainees or researchers to enroll in the program
    • Requires individual to establish lab or company, or accept a faculty position or other appointment, in the foreign country
    • Prevents individual from terminating the talent program contract or agreement except in extraordinary circumstances
    • Limits individual's capacity to carry out a research and development award, or requires individual to duplicate federal research and development award
    • Requires individual to apply for funding from the foreign government with the sponsoring foreign organization as the recipient
    • Requires individual to omit acknowledgment of MIT or the federal research agency sponsoring the research and development award
    • Requires individual to omit the talent program from federal or MIT disclosures
    • Requires individual to maintain conflict of interest contrary to federal awards
    • Incentives to physically relocate to the foreign state. Of particular concern are those programs that allow for continued employment at U.S. research facilities or receipt of U.S. federal research funds while concurrently receiving compensation from the foreign state.
    • Focus on individual researcher instead of project/subject matter
    • Remuneration (salary, stipend, research funding, etc.) significantly above “market” for expected activities
    • Foreign entity title for researcher implies greater connection than underlying facts
    • Foreign residency application encouraged or facilitated
    • Requires changing of researcher’s primary institute affiliation for purposes of journal citations
    • Fundamental research purpose unclear or undefined
    • Requirements to recruit or train other talent recruitment plan members, circumventing merit-based processes

    Slides 17-19 of the Office of Science Technology and Policy presentation “Enhancing the Security and Integrity of America’s Research Enterprise” provide examples and explanations of problematic contractual clauses and behavioral practices. If something appears to be too good to be true, you should question it.

If you suspect you have been contacted by or become associated with a malign foreign talent recruitment program, contact MIT Research Compliance (research-compliance-help@mit.edu). 

Certification and Sponsor Policies

Many federal sponsors require senior/key personnel to certify that they are not participating in a malign foreign talent recruitment program at proposal stage and throughout the award. Review specific funding opportunities for additional terms and conditions.

For ARPA-H, DOD, DOE Office of Science, and NASA proposals and awards, this certification is done through MIT processes. Until all senior/key personnel have completed the certification, these proposals will not route to RAS, and awards will be on hold. To certify:

For more assistance with ARPA-H, DOD, DOE Office of Science, and NASA certification, contact ra-help@mit.edu or review:

Other sponsors may require certification through agency-specific systems. Review sponsor policies:

Impact on Researchers and MIT

Association with a malign foreign talent recruitment program by members of the US academic community  has led to, in various cases:

  • Ineligibility to receive federal research funding
  • Criminal investigation
  • Loss of employment

Updated January 20, 2026