Receiving Gifts from Foreign Entities

What is the Risk?

Gifts or other forms of in-kind support could potentially become a vehicle for foreign influence, to the extent that there are “soft deliverables” involved – i.e., informal, informational exchange opportunities with the donor concerning research results associated with the gift. Recent foreign influence cases at other research institutions have also illuminated the connection between internationally based resources extended to U.S. Principal Investigators (PI) (e.g., laboratory resources or student research support coming from a foreign institution) and potential errors and/or omissions in required Conflict of Interest and Commitment reporting. Florida state law prohibits state universities, state colleges, and their employees and representatives, from soliciting or accepting any gift in their official capacities from a college or university based in a foreign country of concern, or from a foreign principal. Both Federal and State Law require biannual reporting of Gifts and Agreements with a Foreign source that meet a certain threshold. 

FIU’s Response:

FIU addresses this concern on numerous fronts. Annually, FIU complies with all HEA 117 disclosure requirements concerning foreign source gifts and funding. For purposes of proposal submissions, ORED has enhanced its data gathering and verification processes to capture international forms of support which a PI receives (whether directly related or unrelated to the proposal submission.) Conflict of Interest and Conflict of Commitment disclosure processes and visual compliance screening have been enhanced to capture potentially relevant data points.

If any of these measures indicates a potential foreign influence issue, we will assess the risk to the institution and the individual staff member involved so as to formulate an appropriate response.

If you are invited to receive a gift or other support from an international individual or entity and are considering receiving such gift, please contact University Compliance and Integrity and/or complete FIU’s Gift Acceptance Questionnaire to determine how federal and state requirements may apply to the proposed transaction.