Improper Foreign Government Influence

Foreign Influence

This information is to assist researchers in satisfying certain reporting and disclosure obligations. Specifically, UCSF faculty and other researchers are obligated to completely and accurately disclose all financial and non-financial interests and support, affiliations, activities and relationships with foreign entities. Federal agencies such as National Institutes of Health (NIH) and Department of Defense (DOD) have issued statements expressing growing concerns over the potential for foreign influence in the following areas:

  1. failure by some researchers to disclose substantial contributions of resources from other organizations, including foreign governments;
  2. diversion of intellectual property to foreign entities;
  3. sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.

Specific guidance will be communicated to the UCSF community in the coming months, but all faculty and researchers should continue to comply with existing obligations, which include:

  1. Federal Funding: Applicants for federal grants must disclose all “foreign components” in their biosketch and "other support" in grant applications and are required to identify any changes in each annual progress report. Additional detail can be found below, and you may consult with your Research Services Coordinator for further guidance.
  1. Conflict of Interest (COI):
    1. All investigators who are conducting Public Health Service (PHS) funded research and all principal investigators conducting research funded by private sponsors and entities such as National Science Foundation (NSF) and Department of Defense (DOD) must disclose certain financial interests, whether domestic or foreign.
    2. Although PHS regulations exclude United States institutions of higher education and US government agencies from certain financial disclosure requirements, investigators must disclose financial interests received from a foreign institution of higher education, and from the government of another country. NIH recently reminded the community of this requirement in NOT-OD-18-160.
    3. Contact [email protected] for further guidance.
  1. Conflict of Commitment (COC): University of California faculty must report time and earnings from certain outside professional activities involving foreign entities (e.g., consulting for a foreign entity that is outside the scope of their professional responsibilities) on an annual basis, and certain categories of outside activities require prior approval. Contact your department chair for further guidance.
  1. Collaboration Agreements: Any materials or information shared with a foreign entity must be covered under a formal agreement (sponsored research, material transfer, data use, confidentiality, collaboration, etc.). Contact your contracting officer or [email protected] for further guidance.
  1. Visitors: Disclose any foreign visitors to your departmental leadership and the Export Control Officer ([email protected]prior to the visit, as on-boarding steps must be taken to ensure compliance.

Best Practice: Any support from a foreign entity (whether financial or non-financial) or foreign engagement that you would acknowledge in public presentations or publications is something that you should also disclose in grant application systems, annual reports and closeout summaries and in university-related COI and COC disclosure forms (as required).

Content adapted with permission from University of California San Diego Office of Research Affairs.

Foreign Influence Resources from UCOP Ethics, Compliance and Audit Services