The Malign Foreign Talent Recruitment (MFTRP) Program Participation Policy at UConn and UConn Health aims to safeguard the integrity of federally funded research. In alignment with the CHIPS and Science Act of 2022, the policy emphasizes international collaboration but prohibits covered individuals involved in UConn research from participating in malign foreign talent recruitment programs which pose research security risks.

Participation in a MFTRP is prohibited for those seeking funding from US federal agencies (such as the Department of Defense (DoD), Department of Energy (DOE), National Institutes of Health (NIH), National Science Foundation (NSF), etc.). Researchers must certify they are not involved with a MFTRP at proposal submission and annually thereafter. Violations may result in disciplinary actions or disqualification from federal research funding.

A Foreign Talent Recruitment Program (FTRP) is an effort by a foreign government (including affiliated institutions of higher education and other affiliate entities) to recruit science and technology professionals and students. While participation in a FTRP will not necessarily impact a researcher’s ability to obtain U.S. federal grant funding, participation in a Malign FTRP will impede receipt of federal grant funding.

A Malign Foreign Talent Recruitment Program (MFTRP) is any program, position, or activity that provides compensation (including in-kind compensation such as research funding, complimentary foreign travel, honorific titles, access to laboratory spaces, and other forms of renumeration) by a foreign collaborator on a U.S. restricted party list OR a foreign country of concern, or an entity based in, funded by, or affiliated with a foreign country of concern (including institutions of higher education or government designees), in exchange for the individual conducting “malign” talent activities.

Currently, the listed countries of concern are China, Iran, North Korea, and Russia, although more countries could be added (or removed) in the future.

Activities that constitute “malign” talent activities can include:

• transferring intellectual property developed through a U.S. federal research grant to a foreign country;
• an obligation to recruit students, trainees, or researchers to the foreign institution of higher education;
• establishing a laboratory or company in a foreign country in violation of a federal research award;
• accepting a faculty position or other employment or appointment in violation of the terms of a federal research award;
• being unable to terminate the FTRP contract except in extraordinary circumstances;
• being limited in capacity to carry out a federal research award due to effort required for the FTRP;
• providing work that substantially overlaps or duplicates a U.S. federal research and development award;
• being required to submit research grant applications to foreign funding agencies on behalf of the foreign sponsoring organization;
• being required to omit acknowledgment of your U.S. home institution or U.S. federal funding agency;
• begin required to not disclose participation in the FTRP; or
• having a conflict of interest or commitment contrary to a federal research award.

Disclosure Requirements

More than anything else, federal funding agencies stress transparency in a researcher’s disclosure of participation in activities abroad. Individuals must disclose participation in a FTRP by:

• Updating the UConn and UConn Health Conflict of Interest (COI) disclosure form within 30 days of participation; and
• Working with UConn and UConn Health Sponsored Program Services (SPS) to update Current & Pending (Other) Support Pages to ensure disclosure to appropriate federal sponsors.

If you suspect involvement in or have been approached by a MFTRP, contact UConn’s Research Security and Compliance Office immediately at researchsecurity@uconn.edu. Fraudulent statements or claims (including intentional omissions) in violation of this policy may result in criminal, civil, administrative or university penalties.

UConn offers a 3 minute overview training on Malign Foreign Talent Program Participation:

 

If you have questions regarding compliance or need further clarification on policies related to MFTRPs, please reach out to the UConn Research Security and Compliance Office at researchsecurity@uconn.edu.