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Foreign Talent Recruitment Program

Introduction

Participation in foreign talent recruitment programs (FTRPs) can involve risks that warrant careful consideration, mitigation, and–in some cases–complete avoidance. Congress, the Federal Bureau of Investigation, and other government organizations view aspects of certain FTRPs as threats to the integrity and security of the national research enterprise. The CHIPS and Science Act (the C&S Act) directs federal research sponsors to maintain policies that:

  • require covered individuals to disclose all participation in FTRPs, and
  • prohibit recipients of federal support from participating in any malign FTRPs (MFTRPs).

Foreign Talent Recruitment Program (FTRP) Definition

The C&S Act does not include a definition of an FTRP, instead directing the White House Office for Science and Technology Policy (OSTP) to develop one. This definition will likely resemble that currently in OSTP’s National Security Presidential Memorandum-33 implementation guidance:

an effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a part-time or full-time position).

Some activities that might constitute an FTRP include an agreement to assist with the establishment or management of a new laboratory abroad without violating U.S. law or policy, being invited to apply for a bona fide part-time appointment appropriately disclosed to University and federal officials, or a research arrangement that encourages publication in a specific foreign country’s academic journals.

What is a Malign Foreign Talent Recruitment Program (MFTRP)?

The National Science Foundation, Department of Defense, and other federal funding agencies are beginning to prohibit sponsored research personnel from participating in Malign Foreign Talent Recruitment Programs (MFTRPs), as required by the CHIPS and Science Act of 2022. But not all foreign talent recruitment programs are malign.

How do you know if an arrangement is a MFTRP?

The arrangement is within the CHIPS and Science Act’s definition of a MFTRP if the following are true:

  • The arrangement is described in Box A below, and
  • has at least one factor from Box B and
  • has at least one factor from Box C.
Box A – Description

Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue—

Box B. - Problematic Obligations/Activities

In exchange for the individual—

  1. engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;

  2. being required to recruit trainees or researchers to enroll in such program, position, or activity;

  3. establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;

  4. being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;

  5. through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;

  6. being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;

  7. being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;

  8. being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity;

  9. having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award;

Box C - Problematic Sponsorship

The program sponsored by—

  1. a foreign country of concern (FCOC), currently defined as:

    • China
    • Iran
    • North Korea, and
    • Russia

  2. an entity based in a FCOC, whether or not the program is directly sponsored by the government of the FCOC

  3. an entity on a US government restricted entity list (see https://www.trade.gov/consolidated-screening-list and contact exportcontrols@purdue.edu for additional information.

  4. an academic institution or a foreign talent recruitment program identified by the Department of Defense here on pages 18-21.

Key contacts

If you have joined a talent program or have questions about these programs, please reach out to Purdue’s Research Security team, Elizabeth Wagner (wagne366@purdue.edu) or Stefani Buster (sbuster@purdue.edu).

Purdue University, in accordance with Section 10638(4)(a)(i-ix) of the CHIPS and Science Act of 2022, expressly prohibits university employees, students, and faculty members from participation in/with malign foreign talent recruitment or malign foreign talent like recruitment programs. Learn more about Purdue policies here: Research Security Program (I.A.6), Conflicts of Commitment and Reportable Outside Activities (III.B.1), Individual Financial Conflicts of Interest (III.B.2).

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