Published October 23, 2025, via Research News
The External Professional Activities (EPA) Policy, specifically Section IV. Prohibited or Restricted Activities has been revised to align with federal requirements and improved clarity. These include language around involvement, including collaborations, with:
- Entities, programs, or persons included on the Government’s Denied Persons and Debarred Lists, which is completely prohibited by federal regulations.
- Entities, programs, or persons on the Government’s Unverified List or Section 1286 [list] of the National Defense Authorization Act (NDAA) is prohibited unless an exception is obtained from the VCR. The Department of Defense recently updated its requirements to prohibit this type of engagement. In addition, many funding agencies view this engagement as a high-risk activity, which may impact receipt of an award.
Best practice is for faculty to contact Export Controls or use the government’s Consolidated Screening List:
- For screening foreign entities and collaborators
- Prior to hosting visitors, or extending offers to staff or trainees coming from Countries of Concern (Republic of Cuba, Venezuela, People’s Republic of China, People’s Republic of Korea, the Russian Federation, and the Islamic Republic of Iran).
Entities are automatically screened for activities disclosed through the EPA disclosure process or related to a contract executed by the University. Individuals where the university is sponsoring their visa are also automatically screened.
The Office of Research Integrity and Ethics has also updated its Guidance for Foreign Talent Programs to align with the policy changes and provide additional information.
As a reminder: external professional activities involving foreign governments or entities must be disclosed to the University. Prior Approval is required for certain activities (foreign or domestic), including outside appointments, employment, external research, or Officer/Board of Director roles. Refer to Disclosure Requirements and Prior Approval Requests for further information.
For questions, please contact the COI team at coi@wustl.edu or 314-747-4181.