The Complex Challenge of Foreign Interference in Research Administration and Compliance

Recently, foreign interference has emerged as an important compliance issue for U.S. research institutions, due to efforts by foreign governments to misappropriate intellectual property and research. Consequently, federal funding agencies are now requiring research institutions to ensure compliance with foreign component regulations and to implement protections against foreign interference. This paper offers an analysis of foreign interference cases and recommendations from national committees and leading academic institutions, summarizing the geopolitical context, compliance risks, risk management strategies, and future challenges in this area. The key risks identified were the diversion of IP and research and non-disclosure of foreign sponsorship. Recommended compliance and risk management strategies include centralized work groups, monitoring and auditing, integration of foreign component compliance into research misconduct and conflict of interest and commitment policies, staff training, and security controls. Special attention should be paid to future regulations and industry standards for dual appointments and foreign talent recruitment programs and compliance with federal deemed-export and equal employment opportunity laws. Finally, foreign interference management programs should also include measures to prevent racial profiling and xenophobia, while emphasizing a commitment to international collaboration, a diverse workforce, and America's open academic system.