Several federal agencies have implemented strict prohibitions regarding participation in maligned foreign talent programs (MFTP). Currently, these agencies include the National Science Foundation (NSF), Department of Energy (DOE), and Department of Defense (DOD).
These prohibitions stem from concerns related to national security, intellectual property theft, or ethical considerations and are designed to prevent individuals or entities from engaging in activities that could compromise U.S. national interests.
While many countries sponsor talent programs for legitimate purposes of attracting researchers in targeted fields, and many programs use legitimate means of attracting talent, talent programs sponsored by foreign countries of concern can encourage or require unethical or criminal behavior as a term and condition of participation. As of May 1, 2024, foreign countries of concern include People’s Republic of China, Russia, Iran, and North Korea.
Principal Investigators planning to pursue funding from NSF, DOE, or DOD must familiarize themselves with these restrictions and communicate them to all program staff prior to proposal submission. See the Research Security Maligned Foreign Talent Program Resource page for definitions and additional guidance. Contact the Office of Research Compliance, Integrity, and Safety immediately if you or any members of your project team believe they may be a party to a MFTP.
SPA has updated the PI certification language in InfoEd to confirm that the PI has communicated this prohibition to all project personnel and that no personnel are participating in a MFTP. All PI and Co-PIs must provide this certification with each proposal.
As a reminder, senior personnel must also disclose any participation in a Foreign Talent Recruitment Program (malign or not) through Biosketches, Other Support Pages or similar documents.
This restriction is part of a rapidly evolving research security framework that the U.S. Government is implementing. SPA and ORCIS are tracking these developments and associated requirements closely with university units including Academic Affairs and the Office of General Counsel.
A policy specific to the MFTP prohibition is expected to be available to campus for review after the start of the fall semester.
Additional training and procedures are planned to support faculty and staff in navigating these requirements while ensuring support for open collaboration in all educational and research endeavors that are central to NIU’s mission.
In case of any uncertainty, please do not hesitate to contact SPA or ORCIS with any questions or additional guidance.
A summary of the agency requirements specific to MFTP are below.
National Science Foundation (NSF)
No individual named as senior personnel may participate in a maligned foreign talent program and all senior personnel must certify that they are not a party to such a program prior to proposal submission. This prohibition is effective for all new proposals submitted on or after May 20, 2024.
Department of Energy (DOE)
Senior personnel funded by DOE contracts or subcontracts (not grants) are prohibited from participating in foreign talent recruitment programs that are sponsored or affiliated with a foreign country of concern. All of NIU’s funding from national laboratories are considered contracts.
Department of Defense (DOD)
Beginning August 2024, DOD will prohibit funding for any fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program or to a proposing institution that does not have a policy addressing malign foreign talent recruitment programs pursuant to §10632 of the CHIPS and Science Act of 2022.
