Performing Research

Please visit Guidance Regarding Foreign Influence and Research for specific guidance and reporting obligations.

What is the Risk?

Today’s research security environment requires that our research community remain aware of not only how Export Control regulations impact international engagement but also Federal and State regulations which are designed to protect research results (including fundamental research) and Intellectual Property from adverse international interests, both economic and geopolitical.

Among key safeguards, funding agencies are now placing significant weight on the timeliness and accuracy of Bio-sketch and Current/Pending Support reporting through PI and institutional certification. Funding agencies presume that researchers are required to comply with a robust institutional Conflict of Interest/Conflict of Commitment disclosure and management process designed to detect and address aspects of international engagement which could render research vulnerable to security concerns.  Advanced search tools now enable government investigators to better understand vulnerabilities which may occur during international collaborative research, hosting Visiting Scholars, co-authorship, and IP licensing among other activities. 

Agencies are now increasingly requiring researchers to certify that they are not participants in Foreign Recruitment Talent Programs, and to take research security training designed to help identify foreign influence efforts. These efforts can take the form of in-kind support, foreign collaboration incentives, international academic appointments, and positioning visiting scholars in U.S. labs through home funding arrangements that require data transfers back to home country institutions - - outside the normal collaborative context.   

Failure to comply with these research security regulations and requirements as they apply to federally and State-sponsored research, as well as industry and internally funded research, can result in significant legal consequences to FIU and individual researchers; debarment from receiving federal and state research funding; and institutional reputational damage.

At the individual research level, the risk is the taking or misuse of research processes and results by adverse foreign interests, or that these types of unintended activities could result in the potential compromise of research ethics.  

Areas of potential inappropriate foreign influence and/or regulatory non-compliance:

1. Personnel may be inappropriately influenced by entities which sponsor their research, provide gifts, and/or provide in-kind support.
2. A foreign entity may gain unauthorized access to federally funded research through support of related research and personnel.
3. Export controlled technology may inappropriately be transferred to foreign entities who sponsor controlled research.
4. Restricted/prohibited or high-risk entities (including but not limited to ASPI-listed institutions) may provide support through sponsoring research, providing gifts, and/or providing in-kind goods and services.
5. A sponsored research project may be at risk if specific foreign influence restrictions or required disclosures by the sponsoring agency are not followed.

FIU’s Response:

FIU strives to sustainably implement research security measures that meet Federal and State of Florida obligations while remaining responsive to the university’s academic mission and research objectives. Toward this end, ORED, FIU’s Office of Research Integrity and Compliance (University Compliance), Office of the Provost, and FIU Global coordinate closely on all aspects of oversight, conduct, compliance and reporting that support research activities. 

Specifically, ORED implements the following research security safeguards:  

• Compiles and updates Federal and State sponsor proposal and reporting requirements  Guidance Regarding Foreign Influence and Research Webpage by covered personnel.  
• Evaluates and screens all candidates applying for research positions under the Florida statute governing foreign influence prevention
• Conducts restricted party screening on industry and international sponsors, subcontractors, and other institutional research partners
• Administers Certifications designed to ensure that no participant of a research project is affiliated with Malign Foreign Government Talent Program
• Evaluates Conflict of Interest (COI) and Conflict of Commitment (COC) disclosures to proactively identify parties of concerns and to support researchers in reporting transactions to federal agencies where required
• Engages in international TAR reviews with University Compliance to identify potential research security concerns associated with proposed travel to Foreign Countries of Concern (FCOCs)
• Evaluates IP licensing and other technology transfer transactions for research security issues.
• Coordinates closely with FIU’s FSO on all Classified research to ensure compliance with the NISPOM and Insider Threat Protection Program.     

In support of research activities, University Compliance along with FIU Global coordinates the process for evaluating

• International travel to Foreign Countries of Concern (FCOC), inclusive of international research activities
• International visiting delegations who may wish to tour STEM laboratories

University Compliance also coordinates other key research security compliance functions such as UAV registration and compliance; HEA 117 Reporting of foreign source funding; and FIU’s restricted party screening program with respect to various categories of international engagement partners.     

ORED Processes, Forms, and Tools:

• ORED utilizes an International Engagements with Restricted/High Risk Parties Matrix (“the Matrix”) to evaluate research security risk in relation to various research-related engagements with international persons and entities. If you would like to request the Matrix, please contact Compliance@fiu.edu.
• As part of proposal submission and award execution, and in addition to the EPRAF, ORED implements an internal checklist to ensure that Bio-sketch and related submissions are timely and comprehensive. Please confer with your award coordinator for details concerning this data capture process.
• Where notification and approval of foreign national (FN) participation is required by a research funding agency, ORED supports this process by coordinating documented FN Notification Plans with the PI and performing post-award checks on this process.
• ORED leverages FIU’s COI/COC Disclosure forms to review all research-related COI/COC matters.

Please contact the ORED team with any specific questions concerning how research security requirements impact funded and non-funded research activities.