Understanding Foreign Influence

“Foreign Influence” is the term used the FBI and other federal government agencies to encompass the potential for foreign actors, particularly foreign state adversaries, to acquire U.S. academic research and information illicitly in order to advance their scientific, economic, and military development goals through the exploitation of collaboration and openness on university campuses. Beginning in 2018 federal funding agencies have issued new guidance and have sought to clarify and/or more tightly enforce existing policies. Congress and the White House have gotten involved, too, introducing new legislation and policy and calling on agencies to produce new information and tighten oversight.

Foreign influence concerns on the part of the US government can be broken out into four major categories:

• Failure to disclose substantial foreign resources:
  • Foreign employment arrangements and talent awards
  • Foreign grant support (creating overlap or over-commitment)
  • “Free labor” in the form of foreign-funded visiting scholars/students
  • Foreign-source grants (and the related transfers of information, know-how, data, person-time)
• Peer review violations
  • Primarily sharing of pre-publication data with foreign researchers
• Failure to disclose significant foreign financial Conflicts of Interest
  • Equity in foreign companies
  • Foreign patents that leverage US tax-payer funded work
• Failure to fully comply with export laws and sanctions regimes
  • Transfer of export-controlled technology (i.e., technology with potential military use where loss could compromise national security) to individuals or entities on the Office of Foreign Assets Control (OFAC) sanctions list (both in U.S. or shipped abroad)

During this period of heightened scrutiny, there have been several federal arrests, with some cases resulting in prosecutions of U.S. researchers while other cases were dropped. The regulatory landscape is still evolving, but federal law enforcement has made it clear that this is an area that will continue to get considerable attention for the foreseeable future.

Agency Specific Guidance

Over the past two years the National Institutes of Health (NIH), the National Science Foundation (NSF) and the Department of Defense (DOD), along with the White House Office of Science and Technology Program (OSTP), have issued various communications to define concerns and issue guidance, and a key focus has been on disclosure.

Below is a list of key communications from the agencies whose funding and guidance is most important to UMass Chan researchers. Please check specific funding opportunity announcements and relevant agency grant policies for individual applications. Note: Because the federal and UMass Chan responses to foreign influence concerns are still evolving we will update these pages as additional guidance becomes available.