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.