Risk-Based Security Reviews of Fundamental Research
DoD requires fundamental research projects selected for award to undergo a risk-based security review for potential conflicts of interest and conflicts of commitment associated with foreign influence. These reviews may consider researcher affiliations, research support, collaborations, and other information relevant to assessing research security risk.
2026 Fundamental Research Security Initiatives
In January 2026, DoD announced additional measures to strengthen research security across its fundamental research enterprise. These initiatives include:
- Prohibiting fundamental research assistance award funding to companies identified under Section 1260H of the National Defense Authorization Act, which identifies certain Chinese military companies operating in the United States.
- Establishing a department-wide Fundamental Research Risk Review Repository to improve collection and sharing of research security information across DoD components.
- Developing automated vetting and continuous monitoring capabilities, where practicable, to identify and address foreign influence risks.
- Conducting additional annual spot checks of research awards.
- Standardizing reporting of current and pending foreign research support.
- Expanding training for personnel responsible for research security reviews.
- Coordinating assessments of research security cases identified through congressional and other oversight activities.
These measures reflect increasing DoD scrutiny of foreign affiliations, support, collaborations, and other relationships associated with DoD-funded research.
Section 1286 Institutions
Section 1286 of the National Defense Authorization Act requires DoD to identify foreign institutions that have engaged in activities that increase the risk that U.S. government-funded research and development may be misappropriated or subject to foreign government interference.
In July 2026, DoD released an updated Section 1286 list identifying academic and research institutions in China, Russia, and Iran. DoD advises U.S. researchers and academic institutions to exercise strict caution when considering collaboration, funding, or data-sharing engagements with institutions appearing on the list.
The Section 1286 list is updated periodically. Researchers should not rely on previously downloaded versions of the list when evaluating a proposed engagement.
What UCSF Researchers Should Do
Researchers receiving or seeking DoD funding should:
- Ensure that required disclosures of appointments, affiliations, current and pending support, and other relevant outside activities are complete and current.
- Conduct required Restricted Party Screenings before engaging with foreign individuals or institutions.
- Contact UCSF Export Control and Research Security before entering into or continuing a research relationship with an institution or individual identified on a federal restricted or proscribed-party list.
- Contact Export Control and Research Security when a proposed collaboration, funding arrangement, or data-sharing activity may involve a Section 1260H company, Section 1286 institution, or other federally restricted or proscribed party.
- Respond promptly to requests from UCSF or DoD for information needed to conduct research security reviews.
Federal lists do not all carry the same legal or research-funding consequences. A party's appearance on a federal list should therefore be evaluated under the specific law, sponsor requirement, award terms, and activity involved.