Frequently Asked Questions - UCI Office of Research

What is Research Security and International Engagement?

Research Security and International Engagement encompasses the federal government's broad concerns related to protecting the U.S. research and development enterprise and promoting national security.

As described in the National Security Presidential Memorandum-33, the federal government is requiring research organizations like UCI to implement a research security program that encompasses the following:

Cybersecurity
Foreign travel security
Research security training
Export control training

The new Research Security and International Engagement team strives to provide coordinated support and helpful resources to help the campus community navigate this evolving compliance area.

What is the Research Security and International Engagement Committee?

The Research Security and International Engagement Committee is charged with promoting and facilitating responsible international engagements and collaborations. This committee will provide recommendations on policies and procedures in this compliance area, review international activity proposals that trigger specific risks, and oversee UCI's research security and integrity compliance and risk mitigation program.

What does the federal government mean by "improper foreign influence" or "undue foreign influence"?

The federal government uses these terms to describe its concerns regarding nefarious actions by nation-states (or their representatives/agents) which could negatively impact the United States' economic competitiveness and national security. The main areas of concern are:

Integrity of the peer review process
Undisclosed foreign resources, including but not limited to: foreign employment arrangements, foreign grant support that creates problem with overlap, or over-commitment, foreign talents programs
Undisclosed significant foreign financial conflicts of interest
Diversion of proprietary or pre-publication information disclosed in grant applications or produced by US-supported research to those not authorized to receive it (theft of intellectual property)
Compliance with regulatory requirements including US Export Control laws and regulations, which establish a set of requirements for the transfer of technology and data to foreign countries and/or foreign nationals in the US and sanctions from the Office of Foreign Assets Control, which restrict interactions with individuals or entities on the sanctions list

As a result of these concerns, the federal government created new legislation and updated disclosure requirements to emphasize the importance for researchers and universities to disclose accurately, properly, and consistently and establish practices to reduce the risks.

How do I comply with Research Security and International Engagement requirements?

What are the common problems with disclosures related to Research Security and International Engagement? What are the red flags?

Failing to disclose all the required information such as foreign outside financial interests, relationships and affiliations.
- Examples:
  - Not including the foreign country location of the organization/entity
  - Not disclosing participation in a foreign talents program as Other Support/Current & Pending Support to the federal agency.
  - Not disclosing receipt of foreign government grants or research funding.
  - Not disclosing position/appointment/time commitment at foreign institutions.
Having inconsistent information across the many disclosures collected for research proposals and awards, conflict of commitment, conflict of interest and other publicly available information (ex. publications).
- For example, disclosing consulting activity in your conflict of commitment form (UC OATS) but not including the income received from those consulting activities in your financial disclosures to Conflict of Interest for your NIH research project.

What are some examples of how other academics have had problems in the area of Research Security & International Engagement?

Below are some of the press releases and news articles related to the results of the federal government's investigations of university researchers:

What is a foreign government sponsored talent recruitment program?

According to a Public Service Announcement published by the FBI in July 2020:

"A foreign-government-sponsored talent recruitment program is an effort to recruit science and technology professors, researchers, and even students, which is directly or indirectly organized, managed, or funded by a foreign government or institution. Individuals are often recruited without regard to citizenship or national origin, and positions may be full or part-time. Foreign-government-sponsored talent recruitment programs often seek to import or otherwise acquire proprietary technology or software, unpublished data and methods, and intellectual property from abroad-sometimes obtained through illicit means-to modernize the foreign nation's military and grow its economy.

Undisclosed obligations to a foreign-government-sponsored talent recruitment program may distort decisions about the appropriate use of taxpayer funds when grant-funding agencies, unaware of an employee's foreign obligations and funding streams, awards an employee a federal grant. Further, for some projects, undisclosed participation may pose risks to U.S. national security as it is not possible to properly assess potential harm without knowing an individual's obligation to a foreign government."

Many federal agencies have restrictions or prohibitions regarding researchers on their sponsored projects participating in a foreign government sponsored talent recruitment program.

Should I stop collaborating with international colleagues?

No.

"UCI embraces and promotes international collaborations because we are dedicated to academic freedom and an open, inclusive academic environment. While we ardently support our international community, we must also remain committed to academic and legal integrity in our non-domestic collaborations, including policies on scholarly relationships in federally sponsored research; sharing of materials, ideas, and information; federal agency and UC disclosure requirements; and data protection."- Chancellor Howard Gillman