Foreign Influence

UNH strongly supports international collaboration and values its partnerships with universities and other organizations worldwide; however, it is important that all faculty members understand the current regulatory and enforcement landscape.

Federal agencies and Congress have recently raised concerns about threats posed by outside influence in academic research conducted in the U.S. Their concerns apply broadly to issues including the loss of taxpayer funded intellectual property, the integrity of the peer review process, and failure to disclose conflicts of interest.  Of particular concern is the unauthorized transfer of scientific and technical information through participation in foreign government talent recruitment programs.   Federal funding agencies have issued new requirements and guidance, federal law enforcement agencies have increased prosecutorial activity, and Congress has developed new legislation and demanded information on how the academic research community is responding to this evolving issue.

Guidance

Federal funding agencies, law enforcement agencies, Congress, and the White House have all issued some form of communication, guidance, new regulations or policies related to dealing with the issue of undue foreign influences on research integrity. Likewise, Higher Education Organizations such as the American Council on Education, the Association of Public & Land Grant Universities, and the Association of American Universities have issued briefings and position papers on this topic. Below you will find links to source documents from select agencies and organizations.

National Institutes of Health [NIH]
National Science Foundation [NSF] 
NSF Commissioned JASON Report

Department of Energy [DOE]
Department of Defense [DOD]
National Aeronautics and Space Administration [NASA]
Association of American Universities [AAU]
Association of Public & Land Grant Universities [APLU]

 

Disclosure of Activities

Comprehensive disclosure of activities ensures transparency and reinforces a researcher’s credibility; alternatively, failing to disclose can invite disproportionate scrutiny, jeopardize funding or career opportunities, and result in legal prosecution. UNH joins federal funders of sponsored research urging that you disclose information about any and all support, whether it’s provided through an organization or directly to you as an individual, as well as reporting all projects and activities that require a commitment of your time. Below we highlight a few of the notices from NIH and NSF on the importance of full disclosure. 

NIH [PHS]
NIH has created a new Protecting U.S. Biomedical Intellectual Innovation web page that addresses requirements for disclosure of other support, foreign relationships and activities, as well as Conflicts of Interest.

NSF
NSF released updated Frequently Asked Questions on reporting Current and Pending Support on 7/30/20. 

 

Additional Concerns with Foreign Engagements

You must also comply with U.S. export control regulations when doing any of the following: traveling internationally and attending conferences; participating in international collaborations; using proprietary information; hosting international visitors; shipping materials internationally; or engaging in any international transactions.

Certain organizations and/or individuals (both foreign and domestic) are subject to sanctions, embargoes, and other restrictions under US law and UNH may be legally prohibited from engaging in certain activities with listed entities. The university uses a software tool to screen and quickly check and document whether a person or an organization is a restricted party. Send an email to export@unh.edu to request access under the UNH license or to request screening of specific organizations and/or individuals.

Certain countries are subject to comprehensive sanctions or targeted sanctions. Since these designations are subject to change and travel would be impacted accordingly, it is UNH Policy that every traveler going abroad on University business must complete the International Travel Registry.  Any University travel to Cuba, Iran, North Korea, Syria and the Crimea Region of the Ukraine must be disclosed via export@unh.edu as early in the planning stage as possible to ensure appropriate government clearance can be requested.

Guide: The Dos, Dont's and Maybes of Foreign Entity Relationships

 

Contact Information

Victor Sosa, Director
Contracts & Export Controls
Phone: (603) 862-2001
Email: victor.sosa@unh.edu