Country of Concern Engagements

Countries of Concern Engagements are activities or relationships that involve significant or meaningful interaction, affiliation, collaboration, or exchange with a foreign entity/individual involving a country of concern (see below). These engagements must be reviewed by the Office of Research (OR) through the Countries of Concern Engagement Tool process before initiating the engagement unless identified as an exception below (see Exceptions) per the Disclosure, Review, and Approval of Engagements Involving Countries of Concern Policy.

Note that country of concern is not the only compliance consideration. Please visit the Export Controls website for additional guidance on international engagements.

Those considering a Country of Concern Engagement must complete the Countries of Concern Engagement Tool. This Tool guides the user through a series of questions that OR will review to provide guidance regarding the potential risks and compliance concerns. The Tool functions best when users provide substantive information about the engagement and upload all related documents.

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    Countries of Concern

    Democratic People's Republic of North Korea (North Korea)

    Islamic Republic of Iran

    People's Republic of China including Hong Kong and Macau

    Qatar

    Russian Federation

    Saudi Arabia

    United Arab Emirates

    Country of Concern Engagement Tool

    Use the Country of Concern Engagement Tool to receive guidance on the potential risks and compliance concerns prior to engaging.

    Click Here

    Exceptions

    The following types of engagements are excluded from this policy because they are subject to other policies and procedures that address the research security and international engagement concerns:

    1. Activities and affiliations disclosed in biographical sketches and other/current & pending support disclosures in federal applications (see the Federal Funding Proposal Review process).
    2. Foreign collaborators, subawardees, components, etc. included in a federally sponsored award or a federal flow through subaward if disclosure was made in the federal funding application that resulted in the award or subaward.
    3. Category I activities or relationships requiring prior approval under APM-025 and APM-671.
    4. Activities subject the Policy for Student International Activities and the Procedures for Student International Activities.
    5. Visa applications subject to UCI’s Foreign Students and Foreign Scholars: Visa Guidelines.

    Review Procedures

    1. DETERMINING WHO IS AN ENGAGEMENT LEADER – An Engagement Leader should be an individual who is involved in the Engagement and who knows the most about. An Engagement Leader is generally a faculty member or senior UCI administrator who self-selects this role.  There can be more than one Engagement Leader.  In cases where it is unclear who should be the Engagement Leader, please contact the Office of Research (OR) at or-rsie@uci.edu for advice and assistance.
    2. DISCLOSURE - Engagement Leaders (or their designees) disclose an Engagement using the Counties of Concern Engagement Tool (“Tool”).
    3. OFFICE OF RESEARCH REVIEW – OR receives and reviews information from the Tool. Because each Engagement is unique, the review will focus on, but may not be limited to, the following:
      • Restricted Parties screening – This screening determines if a foreign entity or individual involved in the Engagement is on any international lists of sanctioned, debarred, or restricted persons and organizations.
      • Export Control review – This review determines if the Engagement complies with U.S. export control regulations and if the Engagement requires a government license.
      • Reputational Risk review – This review identifies issues, concerns, and politically exposed individuals whose involvement in an Engagement may pose increased reputational risk for UCI.
      • Disclosure Requirements review – This review is intended to assist and support faculty by identifying and communicating to them whether they should disclose an Engagement in their federal funding applications (biographical sketches, other/current and pending support disclosures, etc.), in federal award annual progress reports, or to comply with UC/UCI policies, such as Conflict of Commitment and Conflict of Interest.
      • Critical and Emerging Technologies review – This review determines if the Engagement involves a technology identified by the federal government as important to national security or economic development.
      • Enhanced Review and Approval (ER&A) review – This review identifies if an Engagement will require the UC President’s review and approval.
      • Risk Mitigation Plan development (if necessary) – Developing and implementing risk mitigation plans helps to ensure a responsible and successful Engagement.
      • Research Security & International Engagement Committee (RSIEC) referral – This review ensures that Engagements rated medium or high risk are referred to the RSIEC for review and approval.
      • Overall Risk Rating (Low, Medium, High)
      • Other compliance reviews, as applicable

    Risk Level and Approval

    • Low Risk

      When the potential risk is minimal and does not require mitigation.

      1. Approval: Low risk Engagements are administratively approved by OR staff after completing the OR review.  OR staff will communicate approval to Engagement Leaders.

    • Medium Risk

      When the potential risk may require risk mitigation measures to ensure a responsible Engagement.

      1. Approval: Medium risk Engagements receive expedited review and approval by the RSIEC Chair and/or Vice Chair.   Part of the expedited review process is determining whether an Engagement requires a risk mitigation plan. If the expedited review confirms the medium risk or changes it to low risk, the Engagement may proceed after OR staff communicate the review outcome to the Engagement Leader.
      2. Change to High Risk: If the expedited review changes the rating to high risk, then the Engagement is referred to the RSIEC for full committee review and approval.

    • High Risk

      When the potential risk requires a comprehensive risk mitigation plan for ensuring a responsible Engagement.

      1. Approval:  RSIEC full committee review and approval is required for high risk Engagements.  The RSIEC will evaluate the Engagement, associated risks, and the risk mitigation plan, then vote to approve or disapprove.  Once approved, and after OR staff have notified the Engagement Leader and confirmed that the risk mitigation plan is ready to be implemented, the Engagement may proceed.
      2. Disapproval: If a high risk Engagement is not approved by the RSIEC, the Engagement Leader will be notified by the RSIEC Chair or Vice Chair and the Engagement may not proceed.  If the Engagement Leader disagrees with the committee’s decision, they may appeal the decision to the Vice Chancellor for Research, who is the final decision-making authority for Engagements that do not require Enhanced Review and Approval.  An Engagement Leader may submit an appeal request in writing to or-rsie@uci.edu within 15 calendar days of the date they are notified of the RSIEC’s decision.

    • High Risk & Enhanced Review and Approval Required

      When the potential risk requires a comprehensive risk mitigation plan, the Engagement involves Critical and Emerging Technology, and meets the criteria for requiring UC President approval.

      1. Approval: Full committee RSIEC review and approval is required.  The RSIEC will evaluate the Engagement, associated risks, and risk mitigation plan, then vote to recommend approval or disapproval to the Vice Chancellor for Research (VCR).  When approval is recommended, the VCR and RSIEC chair will brief the Provost/EVC and Chancellor.  If approved by the Chancellor, OR staff will submit the Engagement for review and approval by the UC President.  Once the UC President’s approval is received, the RSIEC Chair or Vice Chair will communicate it to the Engagement Leader(s), the RSIEC, and the senior leaders involved in the decision process.
      2. RSIEC Disapproval:  If an Engagement is not approved by the RSIEC, the RSIEC Chair and/or Vice Chair will brief the VCR regarding the committee’s recommendation. The VCR and RSIEC Chair and/or Vice Chair will then brief the Provost/EVC and Chancellor. If the Chancellor does not accept the RSIEC’s recommendation, then the Engagement will proceed as noted above in the Approval section, above. If the Chancellor accepts the RSIEC recommendation, their decision is final, and the Engagement may not proceed. The RSIEC Chair or Vice Chair will communicate decision outcomes to the Engagement Leader(s), the RSIEC, and any senior leaders involved in the decision making process.
      3. Chancellor’s Disapproval: If the Chancellor disapproves the Engagement, their decision is final, the Engagement will not be submitted to the UC President, and it may not proceed.  The RSIEC Chair or Vice Chair will communicate the Chancellor’s decision to the Engagement Leader(s), the RSIEC, and any senior leaders involved in the decision process.
      4. UC President’s Disapproval: If the UC President decides that the Engagement should not proceed, their decision is final, and the Engagement may not proceed.  The RSIEC Chair or Vice Chair will communicate the UC President’s decision to the Engagement Leader(s), the RSIEC, and the senior leaders involved in the decision process.

    Frequently Asked Questions

    On August 23, 2023, President Drake issued a memorandum to Chancellors outlining a comprehensive framework for vetting international engagements involving emerging technology and countries of concern.  The two core principles underpinning the framework are:  i) certain engagements between UC and entities in or associated with countries of concern AND involving critical and emerging technology require review and approval by the UC President (known as Enhanced Review and Approval), and ii) UC locations must establish review procedures for all other engagements involving countries of concern.

    On-going federal government concern about undue influence systematically directed at U.S. universities and research institutions by a handful of countries and their governments is the primary reason why President Drake made this decision.  These countries seek to take advantage of our open environment to gain technological or strategic advantage.  The concern by lawmakers in Washington, D.C., is bipartisan.  As a result, the federal government, through Congress and the Executive Branch, routinely issue communications, guidance, and implement new requirements to address their concerns, which include U.S. national security and foreign policy, as well as efforts to maintain strategic and economic advantages in specific areas.  Leading Federal research agencies, such as the National Science Foundation (NSF) and the National Institutes of Health (NIH), as well as other universities and academic associations like the National Academies of Sciences, have all recognized these emergent risks and issued recommendations on how to thoughtfully consider the risks and successfully navigate them without disengaging from international cooperation and partnerships.

    As the largest public university system in the world, the University of California cannot achieve its mission of education, scientific advancement, and public service without global engagement and an international perspective. UC also benefits immensely from international collaboration and engagement with the global scientific community.  Simultaneously, UC has a responsibility to recognize the inherent risks associated with international engagements involving countries of concern.  Therefore, when engaging in international activities, UC must identify potential risks and create a plan to mitigate and/or minimize them. In addition, UC must ensure that its international activities align with UC ethics and values, and the faculty code of conduct.

    The Office of Research (OR) analyzed the new framework and guidance and presented its analysis to the UCI Research Security and International Engagement Committee (RSIEC).  In August 2024, the Provost and Vice Chancellor for Research accepted the RSIEC’s recommendation to create and implement this Policy.  Between September and November 2024, the OR created a draft policy.  In December 2024, the draft policy was presented to the RSIEC for review, comments, and approval.  In January 2025, key individuals in UCOP’s Research, Policy, Analysis, and Coordination and the Ethics, Compliance, and Audit Services units reviewed and provided comments.  In April, the draft policy was broadly disseminated to UCI faculty, key administrators, the Campus Ethics, Compliance, and Risk Committee, and Council on Research, Computing, and Libraries.  The OR considered comments, questions, and feedback during May, and the final Policy was published in June 2025.

    The Policy requires that all Engagements involving Countries of Concern be disclosed to the Office of Research (OR), that OR review all disclosed Engagements, conduct a risk assessment, develop risk mitigation plans (if required), coordinate the review and approval process for medium and high risk Engagements, and communicate with Engagement Leaders throughout the process.  The Policy also requires that medium risk Engagements receive an expedited Research  Security & International Engagement Committee (RSIEC) review, and high risk Engagements receive a full committee review by the RSIEC.  If an Engagement requires Enhanced Review and Approval by the UC President, the OR is responsible for coordinating submission and communicating the President’s decision to key UCI leadership and the Engagement Leader(s).

    Because the federal government rules about research security and disclosing international engagements are changing on a regular basis, the Office of Research (OR) bifurcated the Policy and procedures so that a future regulatory change would not trigger the policy revision process if the change only required UCI to update its procedures.  This way, we can update procedures accordingly and communicate that change to the UCI community.

    Examples of non-UCI individuals include, but are not limited to:

    • A student from another institution coming to UCI for a short-term research experience.
    • A visiting researcher from another university who does not receive a UCI appointment or is not employed by UCI during the visitation period.
    • A person employed by an external entity (for-profit, non-profit, institution of higher education, government agency, etc.) or who is otherwise acting on behalf of an external entity to engage in UCI research/scholarly activities, whether at UCI or another location.

    The common connection between these examples is that the individuals are engaging with UCI in the context of research or scholarly activities, but they do not have a relationship with UCI either as an employee/appointee (faculty or staff, with or without salary) or as an enrolled student (undergraduate or graduate).

    Examples of being associated with a Country of Concern include, but are not limited to:

    • A faculty member at a U.S. institution of higher education who holds an appointment (paid or unpaid) at an institution of higher education located in a Country of Concern.
    • A student (undergraduate or graduate) at another U.S. institution of higher education who is from a Country of Concern.
    • The U.S.-based subsidiary of a company headquartered in a Country of Concern.
    • An individual employed by or acting on behalf of a Country of Concern’s government.
    • A faculty member on sabbatical from an institution located in Country of Concern who has an academic appointment at their sabbatical institution and where the sabbatical institution is not located in a Country of Concern.

    Engagement Leaders should be the individual(s) who know the most about an Engagement.  In the example provided, the Office of Research (OR) would expect the research project Co-PIs to decide amongst themselves. When deciding who will be the Engagement Leader(s), please consider who will be the best person/people with the most information about the Engagement for the OR to work with so that we can help them successfully management the Engagement from start to finish.

    Engagements involving students from Counties of Concern who are studying at another U.S. institution and who wish to come to UCI for a short-term research experience should be disclosed.  Even though the U.S. State Department issued a visa for the student, it was for the purpose of studying at the student’s home institution.  Therefore, UCI must conduct due diligence in terms of the specific Engagement involving UCI.  Because these students are coming to UCI as visitors rather than enrolled students, UCI has an obligation to screen them as we would other visitors from Countries of Concern.  Conducting due diligence allows UCI to determine what, if any, export control regulations would apply to the Engagement.  It also helps to ensure the Engagement is successful from a compliance perspective, including letting the Engagement Leader know if having the foreign student in their lab will trigger certain disclosure requirements to U.S. federal government research sponsors (such as reporting the Engagement as other support) and when to make such a report.

    Unless the individual is or becomes an enrolled UCI student by the time they arrive, their visit should be disclosed as an Engagement if:

    • they are associated with a Country of Concern, and
    • they will conduct research/scholarly activities, and/or
    • they will use UCI/UC resources or facilities, and/or
    • they have applied to or are participating in a foreign talent recruitment program.

    The OR is sensitive to and understands concerns regarding compressed timelines associated certain Engagements.  Our goal is to expeditiously conduct reviews, coordinate and implement risk mitigation measures, and (when required) help secure approval for an Engagement.  Each Engagement is unique, which is why we encourage Engagement Leaders (or their designees) to disclose as early as possible. 

    No.  Involving enrolled UCI students (undergraduate or graduate) who are from a Country of Concern in UCI research or scholarly activities does not create an Engagement.  However, certain federal rules, such as export control regulations may apply to the research area, research tools, or the student’s home country.  Therefore, it is always advisable to check with Export Control in the Office of Research when enrolled students will work on a research project involving Critical and Emerging Technology.

    This is a scenario that requires careful review of all available information and facts to determine if it is an Engagement, and if so, who should be the Engagement Leader.  Therefore, we strongly recommend that the student’s/postdoc’s UCI advisor/supervisor contact the Office of Research at or-rsie@uci.edu for advice and assistance.

    The internship is an Engagement if it involves any of the following:

    • Critical and Emerging Technology,
    • Conducting UCI research (regardless of location),
    • Using UCI/UC resources or facilities to perform internship-related work,
    • Participation in a foreign talent recruitment program.

     

    Each internship scenario may be unique; therefore, we strongly recommend that the student or the student’s UCI advisor contact the Office of Research at or-rsie@uci.edu for advice and assistance.

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