Performing Research

What are the concerns?

Foreign entities may try to influence the course and outcome of research or gain intellectual property (IP) in advance of publication.  This form of direct influence may lead to loss of IP and inappropriate influence over forthcoming technology, as well as export control violations.  Increasingly many federal sponsors require notification of anticipated foreign national/entity involvement in research (and/or post award involvement that had not been previously disclosed) and may not support continued funding until the foreign involvement is eliminated and/or managed. A sponsored research project may be at risk if specific foreign influence restrictions or required disclosures by the sponsoring agency are not followed.

Institutions are obligated to comply with the Higher Education Act (1965) Section 117 Foreign Source reporting.  The National Defense Authorization Act (2019) also placed restrictions on federal contracts using information platforms and equipment procured from certain restricted parties–again reflecting Washington’s concern over data exfiltration.  In addition, federal sponsors have implemented many changes to their requirements, including required approval for certain foreign nationals, certifications regarding no foreign talent program participation, and requirements to have ORCID IDs. 

Areas of potential inappropriate foreign influence and/or regulatory non-compliance:

1. Personnel may be inappropriately influenced by entities which sponsor their research, provide gifts, and/or provide in-kind support.
2. A foreign entity may gain unauthorized access to federally funded research through support of related research and personnel.
3. Export controlled technology may inappropriately be transferred to foreign entities who sponsor controlled research.
4. Restricted/prohibited or high-risk entities (including but not limited to ASPI-listed institutions) may provide support through sponsoring research, providing gifts, and/or providing in-kind goods and services.
5. A sponsored research project may be at risk if specific foreign influence restrictions or required disclosures by the sponsoring agency are not followed.

Princeton’s Actions:

The Offices of the Dean for Research and the Dean of the Faculty have issued several communications related to disclosures of outside support to federal sponsors. 

In addition, the University has taken steps to address the following areas:

• Development of sponsor/agency disclosure and reporting requirements
• Restricted Party Screening on international sponsors, industry partners, collaborators, etc.
• Internal review processes
• Institutional risk-based decisions to avoid certain categorical engagements.
• Implementation of DPI/ ORCID requirements 
• Guidance documents or other materials.

Processes, Forms, and Tools:

In addition to ORPA’s standard proposal submission documentation, certain sponsors (such as DOE) require certification on a project-by-project basis that no researcher is funded by a foreign talent program or is otherwise affiliated with a foreign entity that might raise foreign concerns.

Sponsors may also require notification and approval of foreign national participants: absent other conditions, this does not necessarily mean a project is export controlled. However, it may be indicative of the sponsor’s efforts to guard against undue foreign influence and/or to implement counterintelligence checks.    

For these projects, ORPA implements specific certification forms as part of the contract execution process and communicates with the PI when such items are required. Please contact your ORPA award coordinator for any questions concerning these types of certifications.