Research Security

WashU deeply values its international collaborations and relationships through our research endeavors and our students and scholars from around the world. These global partnerships enrich our culture and are critical components to providing the highest quality education, research, and patient care.

The U.S. Government has shown increasing concern surrounding foreign influence and international activities. These concerns raise important considerations for understanding and mitigating potential risks to protect our research and prevent undue influence on researchers where foreign entities might try to sway research agendas or gain access to valuable information. Key areas of focus are:

Greater scrutiny of international interests and collaborations; it is imperative researchers be transparent and disclose all foreign affiliations, collaborations, outside financial interests, funding sources, and activities.
Prohibitions on participating in Malign Foreign Talent Programs (MFTP) by the U.S. Government and University policy.
Rigorous foreign risk assessments are being conducted by funding agencies before awarding grants.
Stricter grant requirements, which may restrict certain activities, require data protection measures, require risk mitigation plans, or require Research Security Training [link to this topic].
Heightened emphasis on cybersecurity to protection data from unauthorized access and cyberattacks.

Research Security practices establish safeguards for the research enterprise from actions that could harm national security or economic competitiveness and protects research from theft, foreign interferences, and ethical violations. Transparency and disclosure are critical to navigating this ever-increasing scrutiny on these activities and collaborative relationships.

Current and Pending (Other) Support Requirements

Many funding sponsors require disclosure of Current and Pending (Other) Support in grant and contract applications. Information may be disclosed in a proposal, during the Just-In-Time process, in a progress report, or at any time deemed appropriate by the sponsor.

Federal sponsors are taking an expansive view of what should be disclosed. Reporting should include all your ongoing or proposed research activities, not only those sourced or support through WashU. This includes any foreign sources of funding/in kind support, including equipment, supplies, lab resources and visitors to your lab with foreign support.

Biosketch Reporting Requirements

Biographical Sketches should include international affiliations, such as paid/unpaid appointments, positions, or honors with non U.S. academic institutions. This could include teaching courses or regular student advisory activities.

Disclosing External Professional Activities and Interests to WashU

External Professional Activities associated with any international entity (government, non-profit, for-profit, university/academic), must be disclosed to WashU. Some activities require prior approval.
Personal Agreements: The External Professional Activities Policy requires prior approval for personal agreements/contracts. See the Guidance for Personal Agreements with Foreign Entities for a list of examples and best practices.

Foreign Component Reporting

NIH has specific requirements regarding the reporting of foreign components, see below for details. However, many federal funding agencies may require some type of reporting for foreign collaborations associated with the grant. The best practice is to review the specific agency requirements and, when in doubt, contact your program officer.

Restricted Party Screenings

Restricted Party Screenings are necessary to identify individuals or entities that are barred or otherwise restricted from entering into certain types of transactions with U.S. persons.

Federal Funding Agency Risk Assessments

Agency risk assessments are used to create risk profiles for researchers. A high-risk profile can negatively influence funding decisions by federal funding agencies.

Export Controls

The term “export controls” refers to the federal laws and regulations that deal with the distribution of strategically important technology and information to foreign nationals in the U.S. and persons or entities in foreign countries. Exports include certain financial transactions, disclosures of certain kinds of information, shipments of tangible commodities or software.

These laws may apply if you are:

Hosting foreign nationals in your laboratory (students, postdocs, staff, visitors)
Traveling internationally
Shipping or hand carrying items internationally
Performing international field research
Engaging in international collaborations

Export control laws may require obtaining special approval from the government prior to engaging in these activities and, in some cases prohibit, certain activities altogether.

Travel Security

University-related international travel requires registration for all students, faculty, staff, clinical fellows, and post-doctoral researchers.

Hosting International Visitors

Hosting an international visitor requires a variety of screenings and approvals from a variety of offices at the university.

Foreign Talent Recruitment Programs

The U.S. government has highlighted concerns about certain foreign government-sponsored programs designed to acquire U.S. scientific and technological advancements improperly. These have been deemed “Malign Foreign Talent Programs” (MFTPs), which can pose significant risks to national security, economic security, and your research integrity and potentially creating serious conflicts of interest and commitment. Participation in MFTPs is prohibited by WashU’s External Professional Activities Policy.

Engagement in other types of Foreign Talent Programs (FTPs), are allowable, and must be reported to many federal funding agencies and the University through the EPA disclosure process.