International Collaborations & Foreign Influence

Hosting International Visitors & Sponsoring Visas

Departments sponsoring an individual for an H‑1B, J‑1, TN, or other visa should first contact the Division of Global Engagement (DGE). The Office of Export Controls partners with DGE to screen the visa beneficiary, their home institution, and any funding sources before UO sponsorship proceeds.

If the individual will access specialized scientific equipment or research data, additional steps (such as a Technology Control Plan) may be required. The Export Control Officer will reach out directly when this applies

A TCP is a confidential document that outlines required compliance measures for certain foreign persons involved in specific research activities. TCPs help:

• Identify controlled information, technology, and equipment
• Ensure foreign nationals can fully participate in research
• Prevent unintentional export control violations

Short-term Visitors

Departments hosting short-term visitors who do not require visa sponsorship should contact both the Division of Global Engagement and the Office of Export Controls to assess if there are any required compliance steps before the visit.

Embassy Delegation Visits

The U.S. Department of State requires that embassy delegation visits from certain countries be registered prior to the visit.

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Students, Researchers & Collaborators from China

U.S. export control regulations and federal research sponsors impose restrictions on certain activities involving foreign persons and entities in China.

Many Chinese universities, research institutes, companies, and nonprofits appear on federal restricted‑party lists due to concerns related to national security, military modernization, human rights, cyber activities, or terrorism. Working with these entities may be prohibited or require a license.

Because requirements vary by party and activity, the UO must review each engagement to ensure compliance. Reviews are conducted without discrimination and never limit opportunities based on nationality or immigration status.

he UO will pursue export licenses when needed to support research and collaboration. Licenses can take up to six months, though most activities qualify for documented license exceptions, which must be assessed and documented in advance by the Export Control Officer.

Request Compliance Review

Only the Export Control Officer can determine compliance for activities involving China. Please request a review before beginning any engagement with Chinese institutions or nationals.

Hosting International Students and Visiting Scholars

Use of certain technical or scientific equipment by a foreign person and the release of certain data and information to a foreign person is considered an export to that person's country, even if that person is currently residing in the United States. 

The Export Control Office works with labs, centers, and faculty to classify equipment and identify any restrictions when hosting international scholars, visitors, students, or collaborators.

More About Hosting International Scholars

Travel to China

All travel must be entered into Concur. 

The Office of Export Controls receives travel details directly from Concur and contacts travelers directly if additional information is needed to ensure compliance with regulations. Travelers to China may be required to take a loaner laptop and/or take additional steps to secure data before, during, and after their trip.

More About International Travel

Shipping

Departments shipping materials internationally—other than admissions, marketing, immigration materials, or published research—must submit an International Shipment Form before sending through UO Mail Services or external carriers, such as US Postal Service, UPS, FedEx, or DHL. 

The form provides next steps and, when applicable, a pre‑populated label for UO Mail Services. Most forms are reviewed within one business day, though additional steps may be required depending on the shipment.

Unauthorized shipment of export‑controlled items can result in significant federal civil and/or criminal penalties, including but not limited to temporary prohibitions on international transactions. Departments are responsible for securing required approvals.

More About International Shipping

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Students, Researchers & Collaborators from Iran and Other Sanctioned Countries

The UO supports open research, scholarship, and creative activity. Faculty may have valid reasons to collaborate with scholars or institutions in sanctioned countries, including Iran. These activities are not prohibited, but they do require additional compliance steps under federal export control regulations.

Export control reviews are conducted without discrimination and never limit opportunities based on nationality or immigration status. The UO will pursue export licenses when needed to support academic and research activities. License reviews can take up to six months.

For questions about collaborations or licensing requirements, contact exportcontrols@uoregon.edu.

Request Compliance Review

Only the Export Control Officer can determine compliance for activities involving sanctioned countries.

Please request a review before beginning any engagement with foreign nationals or entities in a sanctioned country, including Iran.

International Students and Visiting Scholars

The UO provides guidance to ensure Iranian students, researchers, and collaborators can fully participate in academic programs while complying with the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and the Office of Foreign Assets Control (OFAC).

OFAC General License G (31 CFR Part 560) allows eligible Iranian nationals on F‑1, J‑1, or H‑1B visas to participate in their approved academic programs at the UO.

OFAC General License G:

• Does NOT authorize the exportation of any UO commodity, software, or technology to Iran.
• DOES authorize the “release” or “deemed export” of certain technology or software to Iranian students if:
  • Such release is ordinarily incident and necessary to the educational program in which the student is enrolled.
  • The technology or software being released is designated as EAR99 under the EAR or constitutes “educational information.”
  • The release does not otherwise require a license from the U.S. Department of Commerce.
  • The student to whom the release is made is not enrolled in school or participating in the educational program as an agent, employee, or contractor of the Government of Iran or a business entity or other organization in Iran. 

Because the above requirements are complex, the Export Control Officer must review any scientific equipment, technology, or software an Iranian national will use or access at the UO, especially for those in STEM fields.

Shipping

The UO is prohibited from sending physical shipments to Iran. While a license may be requested, such applications are generally denied.

More About International Shipping

Travel

Travel to Iran for UO business, including conferences and research, requires an OFAC license in advance.

Register your travel into Concur as early as possible, and at least six months in advance. The Office of Export Controls receives travel details directly from Concur and contacts travelers directly for next steps.

More About International Travel

Current Sanctioned Countries

The Office of Foreign Assets Control (OFAC) administers economic sanctions for the following countries:

• Afghanistan
• Balkans
• Belarus
• Burma
• Central African Republic
• China
• Cuba
• Democratic Republic of Congo
• Ethiopia
• Hong Kong
• Iran
• Iraq
• Lebanon
• Libya
• Mali
• Nicaragua
• North Korea
• Russia
• Somalia
• South Sudan
• Syria
• Ukraine
• Venezuela
• Yemen
• Zimbabwe

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Malign Foreign Talent Recruitment Programs

Researchers with federal funding are prohibited from participating in malign foreign talent recruitment programs under 42 USC 19232: Malign Foreign Talent Recruitment Program Prohibition and federal sponsor regulations.

These programs, typically run by foreign governments in a country of concern, can create conflicts of interest or commitment, enable intellectual property theft, and involve unauthorized transfer of research materials, data, or non-public information. They often impose obligations that conflict with federal award terms.

If you are asked to join a program that meets any of the criteria below, do not sign the agreement and please email us.

Required Annual Certification for PIs

Researchers involved in malign foreign talent recruitment programs are ineligible to serve as PIs on federally funded awards.

PIs should carefully read all certifications and ensure the language in the attestation applies only to malign foreign talent recruitment programs. Questions or concerns? Contact your SPS post-award team.

National Science Foundation (NSF)

The NSF (effective 6/7/2025) requires all principal investigators (PIs) and co-principal investigators (co-PIs) to annually certify in research.gov that they are not party to a malign foreign talent recruitment program. The NSF is expected to expand the annual certification to all senior/key personnel on NSF-funded projects at a future date.

U.S. Department of Agriculture (USDA)

The USDA (effective 8/7/2025) requires all senior/key personnel to annually certify that they are not party to a malign foreign talent recruitment program.

Researchers who have participated in a program within the past 10 years are ineligible for USDA-funded projects that support research and development or science and technology.

National Institutes of Health (NIH)

The NIH (effective 1/25/2026) requires all principal investigators (PIs) and senior/key personnel to certify at the time of proposal and annually thereafter that they are not party to a malign foreign talent recruitment program (MFTRP).

• At the time of the application: PIs and senior/key personnel must certify on their Biographical Sketch Common Form, attached on the R&R Senior/Key Person Profile (Expanded) Form, that they are not a party to a MFTRP.
• Annual Certification at the time of the RPPR: As part of the Research Performance Progress Reports (RPPRs), PIs and senior/key personnel must upload a certification statement in Section G.1, Special Notice of Award and Funding Opportunity Announcement Reporting Requirements as a flattened PDF file. The file for each senior/key person must be named ResearchSecurities_[Name].pdf, where [Name] is the name of the senior/key person.

Permissible International Activities

Under federal law and guidance, international collaborations and activities described below are not part of a prohibited malign foreign talent recruitment program, unless they involve a restricted entity.

Some activities may still require disclosure to sponsors or to the UO and/or export control review. A compliance check helps ensure collaborators are not on restricted lists and helps the Office of Export Controls provide you with guidance on any sponsor disclosure requirements.

Please request a compliance check on international collaborators before beginning any of the activities below. 

Request a Compliance Check

• Scholarly presentations and publishing materials
• Participating in or disseminating information at international conferences or other international exchanges
  • Note: International conferences held in an embargoed or sanctioned country like Iran may require an export control license. The Office of Export Controls uses Concur to identify travel to embargoed countries and contacts the traveler with next steps.
• Participating in research projects or programs that involve open and reciprocal exchange of scientific information aimed at advancing international scientific understanding
  • Note: International research collaborations may require disclosure to federal sponsors and to the UO. See the disclosure section on this website for details.
• Advising a foreign student enrolled at an institution of higher education or writing a recommendation at the student's request
  • Note: Formal advising of a foreign student in an embargoed or sanctioned country like Iran may require an export control license. Please email the Office of Export Controls prior to beginning an advising relationship for a student in an embargoed or sanctioned country.
• Taking a sabbatical in a foreign country, serving as a visiting scholar, or serving as a U.S. government appointee to a board of a joint scientific fund
  • Note: Employees must enter business-related international travel into Concur prior to the trip, even if that travel occurs during a sabbatical.
  • Note: Serving as a visiting scholar may require disclosure to federal sponsors and to the UO. See the disclosure section on this website for details.

Other Foreign Agreements

UO faculty and researchers may be contacted by other foreign entities requesting collaborations with them as individuals.

Before signing such an agreement, we recommend:

1. Requesting a compliance check on the entity to ensure they are not included on any restricted entity lists.
2. Disclosing to your federal research sponsors if needed.
3. Disclosing the outside activity to the UO.
4. Seeking outside counsel to review the language in the agreement, as the university cannot provide legal advice when employees sign contracts outside their work at the UO.

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Disclosure Requirements

Disclosures to Federal Sponsors

Most federal sponsors require researchers to submit biographical sketches and Current and Pending or Other Support documents as part of their proposals. The Department of Energy requires researchers to update their disclosures within 30 days of a change in these documents.

• Biographical Sketch: Outlines a researcher’s qualifications for the project
• Current and Pending or Other Support: Lists all research supports and commitments

Federal agencies are moving toward standardized formats as directed by National Security Presidential Memorandum-33, but the adoption of the formats varies. Most now require a digital persistent identifier (DPI), such as ORCID, to be included in the biographical sketch.

Inaccurate or incomplete disclosures may subject the researcher and the UO to civil and/or criminal penalties under the False Claims Act. The National Science Foundation, the National Institutes of Health, and NASA require updated disclosures within 30 days of the UO identifying an error.

UO Guide to Sponsor Disclosures

Disclosures to UO

Under the Financial Conflict of Interest in Research Policy, researchers responsible for the design, conduct, or reporting of sponsored research must disclose Significant Financial Interests (SFIs) for themselves, their spouse, and their dependent children:

• Annually
• Within 30 days of acquiring a new SFI
• Within 30 days of a change to a previously reported SFI

The Research Administration Portal flags disclosures for renewal 60 days before the annual due date. Disclosures must be up‑to‑date before proposal submission or award processing.

Under the Conflict of Interest, Conflict of Commitment, and Outside Activities Policy, all employees must disclose certain outside activities for themselves, their relatives, and household members that relate to their institutional responsibilities before beginning the activity, even if unpaid or occurring during sabbatical or other approved leave.

Disclosures under both policies are submitted using the Research Administration Portal (Duck ID required). 

Invention Disclosure

PIs must report all innovations before publication to Industry, Innovation, and Translation (IIT) so the federal government can receive its required on-exclusive license.

Working with foreign entities without clearly defining intellectual property rights may cause a PI to lose the ability to:

• Use intellectual property needed for their future research
• Secure intellectual property rights in their work
• Grant intellectual property rights to a sponsor

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Agreements with Foreign Entities

Individual employees are not permitted to sign contracts, memoranda of understanding, material or data transfer agreements, grants, or other types of agreements.

Research Agreements

Agreements sponsoring research activities, regardless of sponsor and monetary value, must go through Sponsored Project Services.

The Office of Export Controls automatically screens foreign sponsors, collaborators, contractors, and subawards entered into the E-proposal Clearance System (EPCS).

Data Use Agreements, Material Transfer Agreements, and License Agreements

Industry, Innovation, and Translation (IIT) manages data use agreements, material transfer agreements, and license agreements.

The Office of Export Controls screens foreign parties on these agreements prior to the execution.

Purchasing and Contracting Services Agreements

The Office of Export Controls automatically screens foreign parties on agreements entered into the Purchasing and Contracting Services Portal prior to execution.

Visit Purchasing and Contracting Services

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Technology Control Plans

Some data, software, technology, and equipment fall under export control regulations. In these cases, they can only be shared with certain foreign persons under an export license or specific conditions.

When restrictions apply, the Export Control Officer partners with the unit to create a Technology Control Plan (TCP).

A TCP is a confidential document that outlines the compliance steps required for certain foreign persons involved in designated research or academic activities.

Why Technology Control Plans Matter

TCPs help researchers:

• Clearly identify controlled information, technology, and equipment
• Support full participation of foreign nationals in research and scholarship
• Prevent unintentional deemed export violations

By making expectations and boundaries clear, TCPs enable safe and compliant international collaboration.

When Technology Control Plans May Be Required

Technology Control Plans (TCPs) are created on a case‑by‑case basis. A TCP may be required when:

• A foreign person participates in research involving controlled equipment on campus
• A foreign person from a comprehensively sanctioned country (Cuba, Iran, North Korea, Syria) engages in research or accesses technology
• A sponsored project involves Controlled Unclassified Information (CUI)
• A foreign person receives access or administrative privileges to high‑performance computing resources
• Additional physical or information security measures are needed to prevent unauthorized access to controlled equipment or data

The UO is committed to international collaboration and does not discriminate based on national origin. TCPs exist solely to ensure compliance with federal regulations, not to scrutinize individuals.

All project personnel review and sign the TCP before it goes into effect.

What Technology Control Plans Include

TCPs start with a standard template. The Export Control Officer, researcher, and unit leadership work together to customized the TCP to the specific context. In some cases, the Export Control Officer may also need to obtain an export license.

While tailored to each situation, TCPs generally address:

• Management commitment to export compliance
• Summary of applicable federal regulations
• Description of the compliance issue
• Federal agency jurisdiction
• Item classification
• Information security measures
• Physical security measures
• Personnel screening procedures
• Training and awareness requirements
• Self‑evaluation procedures

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International Human Subjects Research

Human subjects research conducted abroad or in collaboration with foreign partners may require additional approvals to meet U.S. and international regulations.

Projects with any foreign component are automatically routed to the Office of Export Controls for review.

Researchers must also complete a conflict of interest disclosure and report any relevant conflicts to the Institutional Review Board (IRB), including foreign financial interests or collaborations.

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