International Collaborations and Disclosure Requirements

USC is engaged in far-reaching, global research and recognizes the importance of these international collaborations. To protect the security of the research enterprise, federal sponsors are placing increased emphasis on the disclosure of foreign affiliations, relationships and sources of support, whether they are funded or in-kind support. Conflicts of interest and commitment, especially with foreign entities, are a key focus of the recent National Security Presidential Memorandum 33 (NSPM 33) and the CHIPS and Science Act which are designed to safeguard United States research and researchers. The resources on this page aim to assist faculty in ensuring relationships with foreign entities comply with federal disclosure requirements.

Background Information

“Understanding International Engagement Disclosure Requirements”: Training on TrojanLearn

Quick Guide on Disclosure of Foreign Relationships

Foreign Relationship Reporting Guidance: When and Where to Report

Presentation – International Engagement (Key Considerations)

Memorandum on International Collaborations, Export Controls, and Disclosure Requirements

FAQs on Faculty Foreign Research Relationships

Sponsor Guidance

National Institutes of Health (NIH)

NIH Requirements for Disclosure of Other Support, Foreign Components and Conflicts of Interest (August 2023)

NIH One-Pager On Disclosure Requirements Effective 1/25/2022 – USC Guidance

NIH Update to USC Faculty and Staff Memo (October 2021) – USC Guidance

NIH Changes Explained Slide Deck (June 2021) – USC Guidance

Foreign Interference in National Institutes of Health Funding and Grant Making Processes: A Summary of Findings From 2016 to 2021 (July 2021)

National Science Foundation (NSF)

NSF Biographical Sketch and Current and Pending Support Disclosure Information (summary table updated January 2023)

NSF-approved biographical sketch and current and pending support formats: NSF biographical sketch and current and pending support

NSF FAQs on Current and Pending Support (Effective June 1, 2020; Updated February 2023)

Dear Colleague Letter Regarding Research Protection (July 2019)

Department of Defense (DoD)

DoD Policy on Countering Unwanted Foreign Influence in Fundamental Research (June 2023)

Countering Foreign Influence Program (CFIP) Frequently Asked Questions (FAQ) (Updated May 2022))

DARPA “Senior/Key Personnel Foreign Influence Risk Rubric” (December 2021)

DARPA “Countering Foreign Influence Program” (September 2021)

Memorandum Enlisting University Partnership (October 2019)

Memorandum Regarding Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies (March 2019)

Department of Energy (DoE)

Department of Energy Current and Pending Support Disclosure Requirements (June 2022)

Memorandum Regarding Foreign Talent Recruitment Programs (June 2019)

Government and Association Guidance

Council on Governmental Relations (COGR) Resource Page on Science and Security

Association of American Universities Science & Security

Joint Committee on the Research Environment (“JCORE”) Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise (January 2021)

National Security Policy (NSPM) 33 (January 2021)

NSF JASON Report (December 2019)

In the News

Department of Defense Seeks To Combat Undue Foreign Influence In Higher Education Institutions With Funding Restrictions

Stanford University Agrees to Pay $1.9 Million to Resolve Allegations That It Failed to Disclose Foreign Research Support in Federal Grant Proposals (October 2023)


In the News Archive

Harvard Professor Faces Prison Sentence and Fines for Failing to Disclose Participation in Talents Program (December 2021)

Ohio State Professor Jailed for Three Years for Failing to Disclose Chinese Talent Program Participation and Research Affiliations (May 2021)

Fifty-four scientists have lost their jobs as a result of NIH probe into foreign ties (June 2020)

University of Tennessee Researcher Indicted for For Wire Fraud and Making False Statements About Affiliation with Chinese University (February 2020)

Harvard Professor Arrested for Failing to Disclose Participation in Talents Program (January 2020)

DOJ Reaches $5.5 Million Settlement with Van Andel Research Institute for Failure to Disclose Foreign Relationships (December 2019)

NIH Investigates Foreign Influence (October 2019)

University of Kansas Professor Indicted (August 2019)

Emory Fires Two Researchers for Failure to Disclose Foreign Ties (May 2019)

MD Anderson Ousts Three Scientists for Undisclosed Foreign Relationships (April 2019)

Sponsor Guidance Archive

Upcoming Changes to Biographical Sketch and Other Support Disclosures (effective January 25, 2022) (March 2021)

NIH Reminder on Policies Related to Foreign Support and Financial Conflicts of Interest (July 2019)

NIH Requirements on Investigator Disclosures of Foreign Financial Interests (March 2018)

NIH Definition of Foreign Component

US Innovation and Competition Act (formerly Endless Frontiers Act) (May 2021)

Section 223 of the FY ’21 National Defense Authorization Act (NDAA)(January 2021)