Arizona State University supports academic freedom and the exchange of ideas and collaboration with foreign partners to advance knowledge. We are committed to supporting collaborations with international partners, faculty and researchers from all over the world. It is of great importance for us to maintain our productive relationship with the United States Government and the federal funding agencies that support our faculty in their research and scholarly work.

ASU faculty and staff who have such collaborations are required to be transparent and provide full disclosure of all funded and unfunded collaborations and affiliations as required by federal and state agencies, as well as ASU’s policies.

Federal funding agencies continue to share concerns regarding failure to disclose foreign relationships and activities, which could jeopardize funding eligibility. Many of the federal agencies have released further guidance and we should expect this information may continue to change. We will be providing regular updates, guidance and resources to keep the ASU Research Community up to date and as a reminder of our compliance obligations.

This comprehensive approach will help support consistency, transparency and compliance among our faculty and staff, and will help to meet the requirements of our federal funding agencies.

Want to learn more about foreign interests and international collaborations? Take the CITI Training module entitled “Undue Foreign Influence: Risks and Mitigations.” This training provides a high-level overview of the impact and concerns foreign influence has on academia and is highly recommended. Training can be accessed through the CITI program at citiprogram.org. For information on how to set up an account in CITI see “CITI Training Instructions.”

Best practices for foreign relationships and activities

• Ensure transparency in foreign research collaborations by appropriately disclosing co-authorships, collaborator affiliations, joint appointments, visiting scholar relationships, and contributions to publications, proposals, and sponsored research activities.
  
  Federal sponsors are increasingly scrutinizing relationships involving certain foreign institutions, organizations, and individuals, including:
  
  – Entities identified under Section 1286 list of the National Defense Authorization Act (“NDAA”);
  
  – Organizations appearing on US Restricted Entity List; and
  
  – Entities identified on the DoD 1260H list
  
  Prior professional relationships may also affect future federal funding eligibility, even if those relationships are no longer active. Publication records, proposal disclosures, or renewed sponsor review may bring prior collaborations into consideration.
  
  Faculty should also be aware that former students, collaborators, or professional associates may later become affiliated with entities or countries subject to heightened federal scrutiny. Sponsors may review broader professional and research networks as part of funding or compliance assessments.
  
  These developments may result in additional sponsor inquiries, disclosure requirements, funding restrictions, or limitations on continuing certain professional relationships. Faculty are encouraged to contact [email protected] regarding questions around foreign affiliations or collaborations.
• Refer to the International Research, Research Compliance, and Security Checklist as a resource for all things related to international engagements.
• To fully and accurately disclose domestic and foreign engagements to ASU, including equity interests in foreign entities and/or if you need to update your conflict of interest financial disclosure, contact ASU Research Operations at [email protected].
• Obtain restricted party screening of foreign collaborators and including foreign visitors.  Contact [email protected].
• As you are developing your proposal include a clear description of all foreign collaborations.
• Review your active awards and pending proposals to ensure all locations outside of the United States have been disclosed to the federal agencies and ASU.
• Ensure that any material transfers, data sharing and confidential information are covered by an agreement. Contact the Industry Agreements Group at [email protected] should you need assistance with the development of an agreement.
• Be aware of and follow peer review regulations, including confidentiality provisions related to the content provided during the review.
• Obtain export control review for incoming and outgoing collaborations, including traveling abroad and international requests – whether funded or unfunded.  Contact [email protected].
• For international travel, review the International Travel Checklist and contact [email protected] with any questions.

Additional Information

• Global Operations
• Sponsor Guidelines
• Frequently Asked Questions
• Related Resources

Questions?

Questions should be directed to [email protected].

Inquiries from external funding agencies related to international engagements or requests for institutional endorsements such as letters of support should be directed to Chief Research Compliance Officer (CRCO), Heather Clark at [email protected].