Foreign Influence: Basic Steps for Initiating Internal Reviews of Potential Issues

In the midst of a global pandemic, international scientific collaboration has perhaps never been more important. However, the U.S. government’s efforts to prevent and investigate undue foreign influence in federally-funded research remain active.

Why Foreign Influence Matters

As tensions between the U.S. and various foreign governments increase, accusations of academic espionage by foreign-supported researchers at U.S.-based research institutions are on the rise. The NIH, NSF, DOE, and other agencies are increasingly warning institutions of researchers who have not disclosed foreign associations in compliance with grant funding regulations and other laws. The government continues to initiate enforcement actions and we expect this to increase in frequency and scope during the coming months.

As a result, research and academic institutions in the U.S. need to be ever more vigilant to mitigate brand risk, the loss of federal funds, the risk of undermining intellectual property assets and exposure to enforcement actions.

Basic Steps for Initiating Internal Reviews of Potential Foreign Influence Issues

Whether a U.S. government agency has made an inquiry or an individual researcher has raised concerns about the sufficiency of their own disclosures, many research and academic institutions have found themselves faced with the task of conducting focused reviews into researchers’ current and past affiliations and disclosures. As a result, institutions must be prepared to conduct internal reviews in a thorough and efficient manner. Steps to consider when undertaking such reviews include:

Reviewing grant documentation

  • Determine whether appropriate disclosures were made in grant documentation submitted to federal agencies. For example, when considering NIH grant documentation, key sections to review include biographical sketches, “Current and Pending Support,” “Other Support,” “Facilities and Other Resources,” “Senior/Key Personnel,” and “Foreign Component.”

Reviewing internal disclosures

  • Determine whether foreign affiliations and support have been timely and appropriately disclosed via internal conflict of interest or outside activity reports

Reviewing publications

  • Review the “Acknowledgements” sections for undisclosed grants or support
  • Review author affiliations for undisclosed relationships
  • Review author affiliations to ensure primary affiliation is listed first

Reviewing other open-source information

  • Conduct basic online research to determine if individuals have additional research funding, relationships, labs, etc. that have not been disclosed, including looking at foreign websites
  • This may include online CVs, lab websites, news articles, and press releases
  • Note that English-language versions of websites sometimes eliminate important information that appears on the original foreign-language site

Asking questions, when appropriate

  • Depending on the nature of the review, follow up on information received by interviewing researchers, colleagues, and staff (e.g., COI staff, department chairs, or relevant dean’s office personnel)

Determining whether to seek external assistance

  • If basic review measures above unearth a large number of questions or issues, or indicate that corrective disclosures may be necessary, determine whether the situation warrants seeking outside counsel to help conduct a more in-depth review
  • In some cases, it may be advisable for individual researchers to obtain outside counsel


Printable version.