Federal Government Foreign Influence Risk Reviews

The Department of Defense (DOD) guidance is titled, “Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education”  and includes three documents:

• June 8, 2023, Under Secretary of Defense Memorandum on Policy for Risk-Based Security Reviews of Fundamental Research. (pages 2 – 7)
• DOD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions (“Decision Matrix). (pages 8 – 16)
• FY22 Lists Published in Response to Section 1286 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232), as amended (“Lists”). (pages 17 – 21)

NOTE:  On May 5, 2025, a new DOD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions was released.  

Additional information can be found on the OUSDR&E Basic Research | Research Directorate Academic Research Security page.

All DOD components are required to develop policies and processes for the risk-based security review of proposals for funding for fundamental research projects. The “Decision Matrix” is a guide to be used by Program Managers and DOD components in reviewing proposals for potential conflicts of interest or commitment and to identify “actions prohibited by law that would preclude an investigator or institution from receiving funding from the Department.”

The DOD documents specify requirements for these policies and include a matrix of risk factors, some of which are prohibited or must be addressed via mitigation measures, and others for which mitigation measures are recommended, suggested, or not required. The matrix includes four key factors:

• Foreign Talent Recruitment Program Factors
• Funding Sources Factors
• Patent Factors
• Entity Lists Factors

WHAT DOES THIS MEAN FOR UMD RESEARCHERS SEEKING DOD AWARDS?

DOD components are conducting risk reviews of fundamental research project proposals and are notifying university research officials of proposals with identified Countering Foreign Influence Program (CFIP) issues.  In at least one instance, the DOD component noted that the CFIP assessment was based on materials submitted by the PI or openly available on the internet.  In those instances where mitigation measures are possible, research security personnel will engage with the DOD component representatives to learn the nature of the concern and will work with the PI and relevant university officials to determine appropriate mitigation measures, should the PI elect to continue with the project.

NOTE REGARDING ARMY RESEARCH

In the spring of 2024, the Army Research Lab published a Risk Matrix/Rubric and FAQs as it implemented the AFC Army Research Risk Assessment Protection Program to "help identify and mitigate existing or potential risk of CoC/CoI in Army research grants and cooperative agreements."  Risk ratings run from High to Low in each of the four risk factor categories:

• Foreign Talent Program
• Denied Entities
• Funding
• Foreign Institutions

Of note, this matrix includes co-authorships and panel participation at a conference with foreign entities/institutions as a part of the risk assessment: "co-authorship/panel participation at a conference is an indicator of collaboration between researchers and research institutions to exchange something of value. Co-authorship/panel participations at a conference with a strategic competitor would be considered under Factor 4: Foreign Institutions of the Army rubric."

On July 10, 2025, the U.S. National Science Foundation issued Important Notice No. 149:  Updates to NSF Research Security Policies.  The six primary tenets of the notice are: 

1. Research Security Assessment and Required Recipient Documentation – Effective October 10, 2025**
2. Research Security Training – Effective October 10, 2025
3. Malign Foreign Talent Recruitment Program Prohibition – In Effect
4. Malign Foreign Talent Recruitment Program Certification – In Effect
5. Foreign Financial Disclosure Reporting (FFDR) – In Effect
6. Certification Regarding IHEs Hosting or Supporting Confucius Institutes – Effective October 10, 2025.

NSF, in June 2024, announced a new risk mitigation process, the Trusted Research Using Safeguards and Transparency (TRUST) framework, which NSF will use in assessing grant proposals for potential national security risks. According to the announcement, the TRUST process will be rolled out in three phases. “Beginning in FY 2025, the process will be piloted on quantum-related proposals. The pilot will collect data and assess key metrics, monitor the impact on NSF directorates and build and evaluate NSF's ability to review the potential national security applications of NSF-funded technology.”  This process will include, but is not limited to, consideration of four U.S. government lists, including the Entity List, the 1260(H) list, the 1286 list, and the Annex of E.O. 14032.  (See bottom of this webpage for links.) “In the second phase, lessons learned from the pilot phase will be implemented and the process will be expanded to include other key "CHIPS and Science Act of 2022"technology areas. In phase 3, NSF will scale up the review process to include all key technology areas and/or the priorities of the NSF Technology, Innovation and Partnerships Directorate's priorities.”  The OCRSSP TRUST Policy Memo was issued by the NSF Office of the Chief of Research Security Strategy and Policy Office, and provides additional detail, including a graphic depicting the TRUST process.

**Pursuant to the July 10, 2025 notice, "NSF reserves the right to perform risk assessments, using analytical tools, of proposals and awards submitted to the Foundation to assess nondisclosures of required information from senior/key personnel, and establish other policies and procedures for identifying, communicating, and addressing security risks that may threaten the integrity of Foundation-supported research and development.

NSF proposers and recipients are required to maintain supporting documentation, including copies of contracts, grants, or any other agreements specific to foreign appointments, employment with a foreign institution, participation in a foreign talent recruitment program and other information reported as current and pending (other) support for all senior/key personnel that must be available to NSF upon request. Proposers and recipients are expected to review requested supporting documentation for compliance with NSF award terms and conditions."

On November 26, 2024, the Deputy Secretary of the Department of Energy released the Department of Energy Research, Technology, and Economic Security Framework for Financial Assistance and Loan Activities Memo.  The memo includes an overview of DOE’s goals, process, high-level risk factors, and commitment to mitigation.

On August 15, 2024, NIH released a Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel.  Additional information is contained in a post titled, “New Decision Matrix Further Clarifies NIH Processes for Handling Allegations of Foreign Interference,” from Dr. Mike Lauer, NIH Deputy Director for Extramural Research.

On September 11, 2025, NIH issued NOT-OD-25-154, Implementation of NIH Research Security Policies.  This notice details research security training requirements and Malign Foreign Talent Recruitment Program prohibitions and certifications.  

On December 2, 2025, NIH issued NOT-OD-26-017 Research Security Training Requirements for NIH.  This directive requires each covered individual (for NIH this is defined as senior/key personnel) listed on an NIH grant application to certify that they have completed RST within 12 months of the date of application submission.

On February 4, 2026, NIH issued NOT-OD-26-033 Adjusted Timeline for NIH’s Implementation of Common Forms.  This directive provides updated guidance to the extramural community regarding an adjustment to the timeline of NIH’s implementation of Common Forms for Biographical Sketch and Current and Pending (Other) Support. NIH will be extending the current leniency period through May 2026.

On July 8, 2025, the Secretary of Agriculture issued Secretary's Memorandum SM 1078-014 titled, America First Memorandum for USDA Arrangements and Research Security.  Within 30 days, all USDA mission areas, agencies, and offices were required to must submit a detailed list of existing arrangements with foreign persons or entities or U.S. persons or entities under foreign control or influence.

For proposed future agreements or extending letters of invitation to conduct any activities with any foreign person or entity or any U.S. citizen or entity subject to foreign ownership, control, or influence, all USDA Mission Areas, Agencies, and Staff Offices are required to submit the draft arrangement along with a justification to the Office of Homeland Security, the Office of General Counsel, and the Office of the Chief Scientist that answers a series of questions listed in the memo.  

Importantly for researchers and the researchers' employing institution, the Memo also lists a number of terms and conditions which must be met to enter into an arrangement with USDA related to research and development (R&D) or science and technology (S&T).

USDA issued the General Terms and Conditions for Federal Awards which became effective December 31, 2025.