Regulatory Landscape

The UO works closely with federal agencies and campus partners to ensure compliance with U.S. export control and research security regulations. Export control regulations govern how certain items, software, technologies, and services can be shared with foreign countries or foreign individuals. Research security regulations safeguard federally funded research from undue foreign influence. Federal research sponsors may impose additional requirements, and the UO maintains its own policies to support compliance across campus.

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Federal Export Control Regulations

NSPM-33

CHIPS and Science Act

Federal Sponsor Agencies

Federal Export Control Regulations

U.S. Department of Commerce

The Bureau of Industry and Security's Export Administration Regulations (EAR) control the export, re‑export, and transfer of “dual‑use” items. Dual-use items refer to technologies, software, equipment, and information that are primarily civilian in nature, but could also have military or national‑security applications.

U.S. Department of State

The Directorate of Defense Trade Controls administers the International Traffic in Arms Regulations (ITAR), which apply to defense‑related items, services, and technical data, including satellites and spacecraft. The U.S. Department of State also provides guidance on defense services and fundamental space science research.

U.S. Department of the Treasury

The Office of Foreign Assets Control (OFAC) enforces economic sanctions and trade embargoes. These restrictions may limit or prohibit activities—including educational services—with certain countries, entities, and individuals.

Fundamental Research Exclusion

Most university research qualifies as “fundamental research,” meaning the resulting information is intended to be published and is generally exempt from export controls. However, the university must formally document this determination. Individual departments should not make this assessment on their own.Key federal guidance includes:

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National Security Presidential Memorandum-33

On January 14, 2021, President Trump issued National Security Presidential Memo (NSPM)-33 to strengthen protections of government supported research and development against foreign interference and exploitation. NSPM-33 requires research institutions that receive more than $50 million per year in federal science and engineering support for the previous two fiscal years to operate a research security program.

NSPM-33 interim implementation guidance was released January 2022, and final implementation guidance was released July 2024.

A research security program must include: 

  1. A cybersecurity program consistent with the National Institute of Standards and Technology guidance. This guidance is forthcoming.
  2. Foreign travel security that includes periodic training for covered individuals and reporting requirements.
  3. Research security training for covered individuals and an institution's certification of individuals' completion of such training.
  4. Export control training for covered individuals who perform research and development involving export-controlled technologies and processes for reviewing foreign sponsors, collaborators, and partnerships.

Under the final implementation guidance, federal research agencies may develop additional requirements for research security programs beyond the four elements above.

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CHIPS and Science Act of 2022

The CHIPS and Science Act requires:

  • Researchers on federal research awards to complete annual research security training. (Section 10634)
  • Researchers to certify at the time of proposal submission and annually during the duration of an award that they are not part of a malign foreign talent recruitment program. (Section 10632)
  • Institutions to certify that researchers are aware of the prohibition of participating in malign foreign talent recruitment programs. (Section 10634)

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Federal Sponsor Agencies

In addition to the U.S. Departments of Commerce, State, and Treasury, many federal agencies who sponsor research have their own regulations related to international research collaborations with the goal of mitigating foreign influence in research.

The National Defense Authorization Act, signed in August 2018, included Sec.1286, which stated, “The Secretary of Defense shall, in consultation with other appropriate government organizations, establish an initiative to work with academic institutions who perform defense research and engineering activities…to limit undue influence, including through foreign talent programs, by countries to exploit United States Technology…”

National Institutes of Health (NIH)

  1. NIH's website on foreign interference
  2. NIH's decision matrix for assessing potential foreign interference for covered individuals
  3. NIH's FAQs for Other Support and foreign components
  4. December 2, 2025: NOT-OD-26-018. NIH’s Implementation of Common Forms for Biographical Sketch and Current and Pending (Other) Support for Due Dates on or after January 25, 2026. This notice implements the Common Forms for biographical sketch and current/pending or other support documents.
  5. December 2, 2025: NOT-OD-26-017. Research Security Training Requirements for NIH. This notice requires PIs and senior/key personnel to complete annual research security training.
  6. July 18, 2025: NOT-OD-25-130. Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects. This notice describes the new process for establishing foreign subawards on NIH grants.
  7. July 17, 2025: NOT-OD-25-133. NIH Announces New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements. This notice requires PIs and senior/key personnel to complete training on the disclosure requirements for their Other Support document.
  8. May 1, 2025: NOT-OD-25-104. Updated NIH Policy on Foreign Subawards. This notice informs the research community that NIH will no longer approve requests to add a new foreign component or subaward to an ongoing NIH-funded project.
  9. April 2, 2025: NOT-OD-25-083. Implementation Update: Enhancing Security Measures for NIH Controlled-Access Data. This notice prohibits access to NIH Controlled-Access Data Repositories and associated data by institutions located in countries of concern. These countries include China (including Hong Kong and Macau), Russia, Iran, North Korea, Cuba, and Venezuela.
  10. November 14, 2023: NOT-OD-24-029: Clarification of Implementation of the NIH SBIR and STTR Foreign Disclosure Pre-award and Post-Award Requirements. This notice clarifies some components of implementing foreign disclosures on SBIR/STTR awards.
  11. June 12, 2023: NOT-OD-23-139. Implementation of the NIH SBIR and STTR Foreign Disclosure Pre-award and Post-award Requirements. This notice implements additional disclosure requirements for SBIR/STTR awardees. They must disclose foreign relationships.
  12. September 16, 2022: NOT-OD-22-210. Financial Conflict of Interest (FCOI) and Other Support Reminders. This notice reminds the research community of what financial interests researchers must disclose to the NIH.
  13. May 25, 2021: NOT-OD-21-073. Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates On or After May 25, 2021. This notice implements the use of Common Forms for biographical sketches and current/pending or other support documents.
  14. July 10, 2019: NOT-OD-19-114. Reminders of NIH Policies on Other Support and on Policies Related to Financial Conflicts of Interest and Foreign Components. This notice specifies that researchers must report all resources made available to them in support of their research. They must also disclose foreign activities, regardless of whether or not they have monetary value.
  15. June 19, 2019: Report from NIH Advisory Committee to the Director on foreign influences on research integrity
  16. August 20, 2018: NIH Dear Colleague Letter NIH Director Francis Collins issued a Foreign Influence Letter to Grantees and testified to the Senate Health, Education, Labor, and Pensions Committee regarding concerns about systematic programs of foreign influence in U.S. research.
  17. December 2018: Initial report from NIH Advisory Committee to the Director on foreign influences on research integrity
  18. March 30, 2018: NOT-OD-18-160. Financial Conflicts of Interest: Investigator Disclosures of Foreign Financial Interests. This notice specifies what financial interests researchers must disclose to the agency under 42 CFR Part 50 Subpart F.

National Science Foundation (NSF)

  1. NSF definitions used throughout their research security regulations.
  2. NSF's Proposal and Award Policies and Procedures Guide (PAPPG). The PAPPG includes specific information about disclosures researchers must make to the NSF and how to do so.
  3. NSF's implementation of NSPM-33
  4. NSF's Trusted Research Using Safeguards and Transparency (TRUST) Framework
  5. November 2, 2025: Important Notice No. 149. This notice requires PIs and senior/key personnel to complete annual research security training. They must also provide the UO with copies of agreements they have as individuals with foreign entities, and the UO must review those agreements to ensure they do not conflict with an NSF award. This notice further prohibits PIs and senior/key personnel from being party to a malign foreign talent recruitment program.
  6. December 6, 2019: NSF-Commissioned JASON Report was intended to enhance NSF’s understanding of the threats to basic research posed by foreign governments that have taken actions that violate the principles of scientific ethics and research integrity. With the official receipt of the report, NSF will now begin the process of analyzing its findings and recommendations.
  7. July 11, 2019: NSF Dear Colleague Letter: Research Protection outlines NSF's plans to “address emerging risks to the nation’s science and engineering enterprise.”

Department of Energy (DOE)

  1. December 3, 2025: PF 2026-08. This notice requires PIs and senior/key personnel to use the Common Forms for biographical sketches and current/pending support documents.
  2. October 7, 2024: FAL 2025-02. This notice requires PIs and senior/key personnel to complete annual research security training.
  3. June 7, 2019: Directive DOE O 486.1. This director mandates federal and contractor personnel to fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs.

Department of Defense/War (DOD/DOW)

  1. DOD/DOW's Academic Research Security website
  2. Cybersecurity Maturity Maturation Certification (CMMC) requirements on DOD/DOW awards
  3. March 9, 2026: Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions. This notice specifies under what conditions the DOD/DOW will require mitigation measures when a researcher has connections with specific foreign entities. The notice also prohibits collaboration with entities published on numerous restricted lists.
  4. December 9, 2025: Fundamental Research Security Initiatives and Implementation. This notice specifies how the Department of Defense will secure fundamental research from foreign influence.
  5. June 29, 2023: Countering Unwanted Foreign Influence in Department-funded Research at Institutions of Higher Education. This statement specifies the steps DOD/DOW takes to counter foreign influence in research at institutions of higher education. The notice outlines policies for risk-based security reviews of proposals; for research security training and mitigation; and for rejecting research projects based on security risks.
  6. October 10, 2019: This DOD-issued memo discusses the importance of research integrity.
  7. March 20, 2019: This DOD-issued memo outlines disclosure requirements for all key personnel listed on DoD-funded financial assistance agreements.

Department of Education

  1. February 10, 2020: The Department of Education published a proposed information collection to ensure institutions of higher education report gifts or contracts with foreign sources.

Office of Science and Technology Policy (OSTP)

  1. September 16, 2019: Letter to the U.S. research community regarding research security.

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