Foreign Ownership, Control or Influence refers to circumstances in which a foreign individual, organization, corporation, or government has the ability—either directly or indirectly—to influence the management, operations, decision-making, or activities of a U.S. entity in ways that could create national security or research security risk.

FOCI has historically been associated with the protection of classified information and cleared contractors, but it now applies to federally funded research, sensitive technologies, Controlled Unclassified Information and critical research infrastructure.

Key elements of FOCI and Universities

Federal agencies use FOCI as a risk management tool to identify and mitigate situations where foreign interests could improperly influence research.  As a result, many federal awards now include FOCI-related requirements.

Depending upon the award, researchers (covered individuals) may be required to:

  • Disclose foreign relationships, collaborations and affiliations
  • Agree to not enter into any subawards, contracts, or other agreements (including funded or unfunded foreign collaborations that may result in co-authorships) reasonably related to the federal award with foreign adversaries, foreign countries of concern or organizations or any person subject to FOCI, during the federal award period.
  • Comply with any additional FOCI requirements included in the award terms.

In the academic setting, potential FOCI concerns may arise through:

  • Foreign funding, gifts or sponsored research
  • Foreign contracts and research agreements
  • International partnerships and memoranda of understanding
  • Foreign appointments and affiliations of researchers
  • Participation in foreign talent recruitment programs
  • Author/co-authorship on research papers

Foreign collaboration is not prohibited, unless the sponsor has explicitly indicated otherwise. The concern underlying FOCI requirements is whether the connections could lead to:

  • Unauthorized/Improper access to sensitive research, data or technologies
  • Unauthorized technology transfer
  • Bias or undue influence over research activities or priorities
  • Unauthorized access to classified information
  • Risks to national security or U.S. economic competitiveness

Federal agencies may reference potential FOCI using a variety of terms.  e.g., FOCI, undue foreign influence, foreign components, foreign collaborations, foreign connections, foreign interference.

FOCI-related activities at ASU are managed through disclosure requirements and processes, conflict of interest management, research security reviews, export control compliance and due diligence for international collaborations. 

  • Researchers are expected to fully disclose foreign affiliations, appointments, funding, collaborations (funded and unfunded) to federal agencies in Current and Pending (Other Support) and biosketch documents, and to ASU in the ERA MyDisclosures Module.

Researchers are expected to maintain an awareness of their foreign collaborations for any actual or potential FOCI concerns and contact the KE Office of Research Compliance at [email protected] as soon as any are identified.  

For additional resources on foreign collaborations, please see Research Compliance International Research and Global Collaborations.   For FOCI questions, please contact [email protected].   

Additional resources: