Resources

University Policies

• Faculty Holding Appointments at Other Institutions or Organizations (PROV-009)
• Faculty External Consulting and Internal Overload (HRM-045)
• Financial Conflicts of Interest for Research Investigators (RES-005)
• Employee Obligation to Report Potential Conflicts of Interest (FIN-054)
• Managing Export and Sanction Compliance in Support of University Activities (FIN-043)

Note:  These and other University policies are available in the Policy Directory.  Depending on an individual’s appointment, they may also be required to comply with policies and other requirements established by the Provost’s Office, Medical Center, Health System, College at Wise, and/or their College or School.

Provost’s Office Requirements & Guidelines

• Annual Performance Reviews
• Conflicts of Interest, Faculty

Other Institutional Guidance

• University Code of Ethics
• Restricted Party Screening
• Best Practices for Traveling Internationally
• International Studies Office’s Travel and Re-entry

Have a question or concern about foreign influence?

• Email foreigninfluence@virginia.edu for help.

Looking for more information or training on foreign influence?

• Enroll in CITI's Undue Foreign Influence: Risks and Mitigations course.  This course is free for anyone affiliated with UVA.  See instructions above and contact foreigninfluence@virginia.edu if you have any questions.
• Watch the recording of UVA's 10/30/20 Addressing Foreign Influence Concerns webinar featuring Michael Lauer, Deputy Director, Extramural Research, NIH, and Rebecca Spyke Keiser, Chief of Research Security Strategy and Policy, NSF, to get the perspective of federal research sponsors.

Council on Governmental Relations (COGR)

• Science and Security website compiles recent news articles; COGR meeting presentations, reports, papers and comment letters; and other resources related to undue foreign influence and associated topics.
• 1/14/20:  Framework for Review of Individual Global Engagements in Academic Research. This Framework was developed by the COGR Research Ethics & Compliance Committee as a tool to assist institutions with review of individual disclosures of relationships with international organizations. It provides an underlying structure to support the institution's analysis of outside engagements, assess potential risks, and develop strategies for mitigation; it is not prescriptive but rather allows each institution to adapt the Framework based on their policies, approaches, levels of foreign involvement, and risk tolerance.
• 12/19:  Commentary on Disclosing Other Support and Other Resources in Research Funded by the National Institute of Health. This document summarizes COGR's current understanding of of the NIH requirements based on what COGR and its members understand from various NIH representatives in public meetings and other open discussions since the July 2019 publication of NIH Notice NOT-OD-19-114 Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components and the accompanying FAQs.

Association of American Universities (AAU)

• 5/19/20:  Updated Effective Practices Summary (University Actions to Address Concerns about Security Threats and Undue Foreign Government Influence on Campus). A joint publication by AAU and APLU compiling practices in place or being implemented at member institutions.
• 10/19:  Science and Security Resource Document. (10/19)  Details steps that universities have taken to be more vigilant over the security of research facilities and programs and measures; ensure compliance with rules relating to export controls, dual use research, and classified information; and to address concerns related to undue foreign influence on university campuses.
• 6/5/19:  Statement on National Security Oversight Opportunities and Policy Solutions.  Submitted to the Senate Finance Committee outlining the important work universities do to protect scientific research efforts.
• 4/22/19:  Effective Practices Summary.  A joint publication by AAU and APLU compiling practices in place or being implemented at member institutions to address growing concerns about security threats and undue foreign influence.

Association of Public and Land-grant Universities (APLU)

• 8/23/18:  APLU Statement on New Efforts to Bolster NIH-Funded Research Security  Issued in response to concerns raised by NIH Director Francis Collins in testimony before the U.S. Senate Committee on Health, Education, Labor, and Pensions.

America Association of Medical Colleges (AAMC)

• Research Security and Undue Foreign Influence at U.S. Academic Institutions.  This website is an ongoing compilation of articles and resources related to science and security, primarily focused on NIH actions.
• 11/4/19:  Foreign data theft:  What academic institutions can do to protect themselves.  AAMC News article. Originally published 5/28/19, with the title Combatting undue foreign influence at U.S. research Institutions.
• 7/19:  NIH Concerns and Actions Related to Undue Foreign Influence at U.S. Research Institutions.  This was a memo released by AAMC to their members summarizing recent issues highlighted in Congress, federal science agencies, and the media. 

Coming soon...

For information on U.S. government sponsors' requirements, communications, and other guidance related to foreign influence, please visit the Sponsor Information page.  Recent federal criminal charges and convictions that broadly fall under the umbrella of undue foreign influence are available on the Enforcement Actions page. 

WHITE HOUSE

Presidential Actions

• 1/14/21: National Security Presidential Memorandum (NSPM) - 33 on United States Government-Supported Research and Development National Security Policy.  Press Release, Fact Sheet and NSPM-33 (full text).
• 6/22/20: Proclamation Suspending Entry of Aliens Who Present a Risk to the U.S. Labor Market Following the Coronavirus Outbreak.  While not issued due to undue foreign influence concerns, this proclamation is expected to have some impact on University research activities because it suspends issuance of H-1B and certain other visa types to individuals applying from outside the US.  At this time, it is not expected to impact individuals already in the US.
• 5/29/20: Proclamation on the Suspension of Entry as Nonimmigrants of Certain Students and Researchers from the People's Republic of China.  Directs consular officers to deny visas (F and J) to graduate students, postdocs, and visiting scholars/scientists in certain fields who have current or past affiliations with institutions involved in China's Military Civil Fusion Program (MCF).  The Proclamation also directs State to conduct a review of current F and J visa holders meeting the same criteria in the following 60 days and to make recommendations for possible action.  Note:  This proclamation does not impact undergraduate students from China, nor is it expected to impact Chinese visitors in non-technical fields.
• 5/29/20: Fact Sheet on President Trump's Actions to Counter MCF.

Office of Science and Technology Policy & Joint Committee on the Research Environment (JCORE)

JCORE was established by the National Science and Technology Council (NSTC) in May 2019.

• 1/19/21: The Subcommittee on Research Security, Joint Committee on the Research Environment (JCORE) of the National Science & Technology Council "Recommended Practices for Strengthening the Security and Integrity of America's Science and Technology Research Enterprise" report was released by the Office of Science and Technology Policy (OSTP). 
• 6/23/20:  Enhancing the Security and Integrity of America's Research Enterprise (pdf of slides) presentation by Kevin Drogemeier, Director of OSTP, to the Federal Demonstration Project. See also Addressing Foreign Interference and Associated Risks to the Integrity of Biomedical Research, and How You Can Help, an Open Mike article in NIH's Extramural Nexus posted by Mike Lauer, NIH's Deputy Director of Extramural Research, on 7/8/20.  
• 1/27/20:  American Association of Universities response to JCORE request for Information on the Research Environment.
• 11/19:  JCORE Summary of the 2019 White House Summit
• 7/19:  Update form the NSTC JCORE

SENATE

Senate Subcommittee on Investigations

• 12/6/19:  American Council on Education's letter submitted to Senator Portman in response to the update submitted by the Department of Education Office of General Council. 
• 11/27/19:  Letter from the Department of Education Office of General Council update on the department's activities under Section 117 of the Higher Education Act, as amended.  In short, Section 117 requires U.S. colleges and universities to report foreign gifts and contracts to the department and to the U.S. public; the letter characterizes these forms of revenue as foreign influence activities of concern to the department and congress.
• 11/18/19: Threats to the U.S. Research Enterprise: China's Talent Recruitment Plans (staff report) provides background information, recommendations, and ongoing efforts by U.S. government agencies to secure U.S. research. Illustrative examples of the types of contracts signed by researchers participating in Chinese Talent Recruitment program are provided in Appendix A: China's Talent Recruitment Plan Contracts.  While this report specifically addresses China's programs, other countries have similar programs and contracts.

Senate Committee on Finance

• 12/17/20: The Government Accountability Office (GAO) report on Federal Research: Agencies Need to Enhance Policies to Address Foreign Influence prepared for the Senate Committee on Finance was released. The report addresses findings and recommendations related to both financial and non-financial conflicts of interest. GAO is making nine recommendations to six agencies, including that grantmaking agencies address non-financial conflicts of interest in their COI policies and develop written procedures for addressing cases of failure to disclose required information.

HOUSE OF REPRESENTATIVES 

• 5/4/20:  Letter to the Department of Education from the top House Republicans requesting information yielded by its ongoing probe into U.S. universities’ underreporting of funding from foreign sources.  The seven signatories were the ranking members of the following House committees:  Oversight and Reform; Education and Labor; Homeland Security; Science, Space, and Technology; Permanent Select Committee on Intelligence; Armed Services; and Foreign Affairs.

DEPARTMENT OF STATE

• The Chinese Communist Party's Military-Civil Fusion (MCF) Program.  This website compiles various State speeches, press releases, and diplomatic notes addressing China's MCF program and steps being taken to counter it. 

HEALTH AND HUMAN SERVICES

• 7/8/20:  Addressing Foreign Interference and Associated Risks to the Integrity of Biomedical Research, and How You Can Help, an Open Mike article in NIH's Extramural Nexus posted by Mike Lauer, NIH's Deputy Director of Extramural Research.
• 6/12/20:  ACD Working Group on Foreign Influences on Research Integrity Update.  This report summarizes NIH's findings to date.
• 3/31/20:  NIH Has Acted to Protect Confidential Information Handled by Peer Reviewers, But it Could Do More. Summary released by the Office of the Inspector General.  Complete Report (OEI-05-19-00240) .

EDUCATION

Higher Education Act, Section 117, website provides links to resources related to foreign gift and contracts reporting requirements and ongoing investigations/reviews being conducted.

• 6/22/20: Department launches new online portal for required Section 117 reports of foreign gifts and contracts.  In an email, Sec. DeVos shared links to DoEd's ongoing investigations, the electronic announcement of the new portal (includes access to FAQs and information about what must be reported), and the access point for the new portal. The new portal must be used for the July 31, 2020, reporting deadline.
• 2/27/20:  Information Collection Request; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Foreign Gifts and Contracts Disclosure (Federal Register Notice)
  • 3/11/20:  American Council on Education's comment letter.
• 2/10/20: 
  • 3/11/19:  Council for Advancement and Support of Education's letter to the Office of Management and Budget.
• 12/17/19:  Revised Information Collection Request; Foreign Gifts and Contracts Disclosures (Docket No. ED-2019-ICCD-0114)
  • 12/27/19:  Council for Advancement and Support of Education's comment letter to the Department of Education and the Office of Management and Budget.
• 9/26/19:  : Proposed Information Collection Request; Foreign Gifts and Contracts Disclosures (Docket No. ED-2019-ICCD-0114)
  • 11/5/19:  Council for Advancement and Support of Education's response letter
• 9/6/19:  Information Collection Request; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Foreign Gifts and Contracts Disclosure (Federal Register Notice).
  • 11/5/19:  American Council on Education's comment letter.
• 7/12/19:  American Council on Education's letter requesting for clarification regarding reporting requirements of Section 117.

DEFENSE

• 10/10/19:  Letter from the Under Secretary for Research and Engineering, raising awareness of efforts to combat foreign influence on research integrity. The letter highlights the efforts of JCORE and DOD's participation.
• 3/20/19:  Letter from the Under Secretary for Research and Engineering, describing actions for the Protection of intellectual property, controlled information, key personnel and critical technologies as required by National Defense Authorization Act for FY 2019, Section 1286.

HOMELAND SECURITY

• Countering Foreign Influence Subcommittee. Site provides links to the subcommittee membership list and establishment memo but additional information is expected to be added over time.
  • 5/21/19:  Interim Report.  
• Cyber Infrastructure. Foreign Interference website.

JUSTICE

Federal Bureau of Investigations

• 7/16/20:  Public Service Announcement:  Foreign Government-Sponsored Talent Recruitment Plans, such as China's Talent Plans, Incentivize Economic Espionage and Theft of Trade Secrets.  PSA # 20200716-2.
• 7/7/20:  Hudson Institute Video Event titled China's Attempt to Influence U.S. Institutions: A Conversation with FBI Director Christopher Wray. 
• Combating Foreign Influence.  Part of the FBI's "What We Investigate" website launched 8/30/18. 

China Initiative

• 2/6/20:  China Initiative Conference
  • Attorney General William Barr's remarks
  • DoJ Fact Sheet and Compilation of China-Related Prosecutions since 2018 

NATIONAL SCIENCE FOUNDATION

• 12/11/19:  Fundamental Research Security. A report by the independent science advisory group JASON commissioned by the NSF to enhance the agency's understanding of the threats to basic research posed by foreign governments and provide the agency with actionable policy recommendations for improving security while maintaining openness. See the NSF news release 19-023 for additional context.