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Malign Foreign Talent Recruitment Programs and Entities of Concern Guidance

Managing Risks in International Collaborations

Virginia Tech is committed to expanding research, teaching, and engagement activities, as well as making Virginia Tech a destination for the best faculty, students, and partners across the world. The university is equally committed to comply with all laws and regulations that intersect with international collaborations, including newer requirements from United States federal funding agencies designed to identify and mitigate risks with international collaborations, such as Malign Foreign Talent Recruitment programs (MFTRPs). 

Virginia Tech principal investigators, co-principal investigators, and other senior/key personnel are now required to certify on their proposals to federal sponsors that they do not have affiliations with Malign Foreign Talent Recruitment programs. The information below will define Malign Foreign Talent Recruitment programs and the current process for a timely and proper disclosure of these activities to Virginia Tech and to United States federal funding agencies.

A Malign Foreign Talent Recruitment Program is any program, position, or activity associated with a country of concern or entity of concern in such forms as the following:

  • Cash
  • In-kind compensation, including research funding
  • Promised future compensation
  • Complimentary foreign travel
  • Things of non de minimis value
  • Honorific titles
  • Career advancement opportunities,
  • Other types of remuneration or consideration (See 42 U.S.C § 19237).

A foreign affiliation is a funded or unfunded academic, professional, or institutional appointment or position with a foreign government or government-owned entity, whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary). This includes appointments or positions deemed adjunct, visiting, or honorary with research institutions located in a foreign country of concern. (See 15 U.S.C. § 638(e)(16)). 

Principal investigators must certify on the proposal’s Biosketch, SF 424, or other form as applicable that they and all other senior/key personnel are not participating in an Malign Foreign Talent Recruitment program. Currently two federal agencies require the Malign Foreign Talent Recruitment program certification: National Science Foundation (NSF) (Biosketch) and Department of Defense (DoD) (SF 424).

Participation in an Malign Foreign Talent Recruitment program is cause for senior/key personnel to be dismissed from all federally-sponsored research proposals or awards and/or face other consequences. 

How Do Senior/Key Personnel Know They are Participating in a Malign Foreign Talent Recruitment Program?

Follow the process below to determine if Senior/Key Personnel are participating in an MFTRP.

Is the foreign entity affiliation or project sponsored by an organization in one of the following countries?

  • China
  • Iran
  • North Korea
  • The Russian Federation

If the answer to Question 1 is YES, continue to Question 2.

If the answer to Question 1 is NO, skip Question 2 and continue to Question 3.

Do one or more of the following nine prohibited practices represent the researcher’s work or involvement with a country of concern?

  1. Engage in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information;
  2. Require recruitment of trainees or researchers to enroll in a program, position or activity, or accept employment at a foreign entity;
  3. Establish a laboratory or company, or accept a faculty position, or other employment in a foreign country;
  4. Be unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
  5. Be required to engage in work that limits capacity to carry out a research and development award, or has a substantial overlap or duplication of a federal research and development award;
  6. Be required to apply for or receive funding from a foreign government that would be awarded to the foreign institution;
  7. Be required to omit acknowledgement of the foreign institution, or any United States federal research sponsors;
  8. Be required not to disclose affiliation or participation with the foreign institution to Virginia Tech or the United States federal government in a program, position, or activity;
  9. Have a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award.

If the answer to Question 2 is YES to one or more of the prohibited practices, or one is not certain if a foreign party participates in prohibited practices, STOP and contact for assistance.

If the answer to Question 2 is NO, continue to Question 3.

Does the foreign collaborator appear on one or more United States restricted party screening lists? To answer this question, submit organization names and/or individual points-of-contact names to

If there are no intersections with activities defined under Malign Foreign Talent Recruitment programs, and United States restricted party screening lists do not identify any issues, the senior/key personnel may certify as “not participating in an Malign Foreign Talent Recruitment program” on the Biosketch, SF 424, other forms as applicable.

Note: Senior/key person participating in a Malign Foreign Talent Recruitment Program MUST terminate participation with that program OR terminate participation in any federally-sponsored programs.