Latest Updated: October 16, 2024

A Foreign Talent Recruitment Program (FTRP) is a program organized, managed or funded by a foreign government to recruit science and technology professionals or students in targeted fields.  Many of these programs utilize grants and research fellowships to encourage researchers to relocate to the foreign country as a means of growing the pool of talent in the respective field.  However, some programs, known as Malign Foreign Talent Recruitment Programs (MFTRPs) encourage, or even require, unethical or criminal behavior or contain requirements that may conflict with the terms of federal research or development awards.  Some MFTRPs may require that the recipient take actions which may pose a conflict of interest, conflict of commitment, or loss of intellectual property to their home institution.  For example, the researcher may be required to establish a laboratory at a foreign institution, accept a position at a foreign institution that conflicts with their commitments to their home institution, or agree to apply for research funding to be awarded ato the foreign institution.  Some MFTRPs may require that the researcher keep their participation in the program secret from their U.S. employer and funding agencies or require that the recipient file patents in the foreign country rather than, or before, filing in the U.S.  Definitions of FTRP and MFTRP are provided below.  

The Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act of 2022 prohibits federal employees, contractors, and awardees from participating in MFTRPs after August 9, 2024.   See this page for sponsor-specific requirements.

NSF: The National Science Foundation (effective May 20, 2024) requires that covered individuals certify that they are not a party to an MFTRP at the time of proposal submission.  In addition, institutions must certify that they have confirmed that the senior personnel associated with a proposal are not part of an MFTRP.  

DoD:  Beginning August 9, 2024, the Department of Defense (DoD) is prohibited from providing funding to or making an award in which a covered individual is participating in a MFTRP or to a proposing institution that does not have a policy addressing malign foreign talent programs pursuant to Section 10632 of the CHIPS and Science Act of 2022.  In addition, DoD conducts risk-based security reviews of proposals.  The risk matrix documents the factors that DoD takes into account when proposing risk mitigation measures for research projects.  

DoE:  The Department of Energy (DoE) has tightly restricted talent program participation since 2019 with DoE Order 486.1A. 

Princeton University has implemented processes to ensure that the University remains in compliance with these requirements.  Grant and contract proposals to federal sponsors must include individual certifications that covered personnel are not involved in MFTRPs, as well as institutional certifications that covered personnel have been made aware of the MFTRP prohibition.  (See the Foreign Engagement Assessment Team and Federal Sponsor Reporting Requirements pages for more information.) 

In addition to prohibiting participation in MFTRPs, federal funding agencies have taken steps to require that federally funded researchers disclose participation in any Foreign Talent Recruitment Program (FTRP).  Should the federal funding agency determine that participation in the FTRP increases the risk to the research project, the agency may require that a risk mitigation plan be implemented for the project.  Princeton University addresses this requirement by, as part of the annual Conflict of Interest disclosure process, requiring that researchers disclose to the University if they are party to an FTRP.  

Foreign Talent Recruitment Program -

Source: Office of Science and Technology Policy

A foreign talent recruitment program is any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.

Malign foreign talent recruitment program –

(A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual— 

(B) A program that is sponsored by—

The following are not considered malign foreign talent programs:

Please note that note that individual federal funding agencies may have their own definitions of these and other terms.  It is recommended that you refer to the specific agency for further information on these terms.

Frequently Asked Questions:

• Who are “Covered Individuals”?

  A Covered Individual is a researcher who contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award. This includes Senior and Key Personnel.  Federal funding agencies have latitude in identifying other research participants as “Covered Individuals,” so it is important to check sponsor requirements carefully.

•  Do I need to disclose participation in an FTRP?

  Federal funding agencies require that every “Covered Individual” disclose whether they are a party to an FTRP when submitting a funding proposal to the funding agency.  How this is disclosed, as well as what information is to be disclosed, may vary by federal funding agency.  It is important that researchers consult with their departmental grant manager and ORPA grant manager to ensure proper disclosure.

• How does an FTRP differ from an MFTRP?

  As noted above, many countries encourage the growth of their local research talent through program designed to attract talented researchers to their institutions.  These programs often involve grants or fellowships to promising research candidates.  

  However, some countries utilize MFTRPs which may incentivize criminal or unethical behavior on the part of the researcher.  The definition of MFTRP (listed above) provides characteristics that may indicate that an FTRP is in fact an MFTRP.

  Of particular importance is the sponsorship of the program.  An FTRP may be an MFTRP if the program is sponsored by a foreign country of concern or an entity based in a foreign country of concern (currently China, Iran, North Korea or Russia), or any other foreign sponsor identified in the National Defense Authorization Act of 2019 Section 1286(c)(8) or 1286(c)(9).  

• Is participation in an MFTRP permitted?

  The U.S. government has determined that participation in FTRPs raises the risk that federally-funded research may be inappropriately obtained by foreign governments.  “Covered Individuals” must disclose participation in an FTRP as part of the proposal submission process.  

  In addition, the CHIPS & Science Act prohibits a “Covered Individual” from participating in an MFTRP.  Failure to disclose or making a false certification may result in civil or criminal penalties.

  It is also important to recognize that many MFTRP requirements may also violate Princeton University policy.  

• How do I know if I am participating in an FTRP or MFTRP?

  The definition of FTRP and MFTRP is provided on this webpage.  Individuals with foreign engagements should review the definitions and characteristics of FTRP and MFTRP.  Questions regarding the definitions may be directed to [email protected]. 

• What is not considered an FTRP?

  The federal government has carved out many activities that federally-funded researchers conduct with international colleagues.  These activities typically do not present a research security risk:

  • Making scholarly presentations and publishing written materials regarding scientific information that is not not otherwise controlled under export control laws, regulations pertaining to controlled unclassified information, or other legal obligations.
  • Participation in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under law.
  • Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student’s request.

• I have foreign collaborators on my research project.  Do they have to certify regarding participation in an FTRP or MFTRP?

  If a collaborator is considered a senior/key personnel on a proposal then they should provide their certification as do all other “Covered Individuals” on the proposal.   

• I ended my participation in a foreign program that contained characteristics of an MFTRP in 2020.  Will I be prohibited from receiving an award from a federal funding agency due to my past participation?

  Federal agencies have clarified that the prohibition on participation in an MFTRP is not retroactive.  Proposers must certify that they are not an active participant in an MFTRP at the time of proposal submission.  

  Note that the DoD Decision Matrix indicates that “Covered Individuals” with past MFTRP participation (up to August 9, 2022) may warrant additional mitigation measures.  

• Who should I contact if I have questions?

  Princeton University's research security program is overseen by the Director of Research Security in the Office of Research and Project Administration.  Please contact [email protected] with any questions.