Foreign Influence & International Activities

The University of Nebraska-Lincoln is committed to its faculty, staff, students, and collaborators in facilitating open and publicly accessible research and scholarly activities both domestically and internationally. However, in some instances, restrictions may be placed on such activity in the interest of national security or protection of trade. This is especially true when federal funding is involved.

Issues surrounding foreign influence and international activities in federally funded research has been an evolving topic in recent months, in which the U.S. Government has shown growing concern.

Please reference the directive for additional information and definitions regarding what a foreign talent recruitment program may look like.

Pending further discussion and resolution at the Federal level, we want to ensure UNL faculty, staff, and students are aware of these requirements and the resources available in order to comply with them. Policies and procedures are already in place for the campus to comply with export control regulations, reporting foreign research support and collaborations, and personal financial interests associated with both foreign and domestic entities. With the heightened sensitivity on these issues nationally, we wish to remind you of your obligations to report on international research and scholarly activities. The following is a list of resources and reporting requirements:

Most international collaborations are not problematic and are actually encouraged. However, researchers are strongly urged to disclose and be transparent regarding their involvement in activities of this nature.

The below guidance also describes how some of the different components within Research Compliance; the Export Control Compliance Program (ECCP) and Conflict of Interest (COI) work to monitor and identify possible concerns:

If you….You should…. RCS Involvement
…have been invited to participate or are currently participating in a foreign talent recruitment program (e.g. foreign 1000 talents program, young scholar 1000 talents plan, etc.), or work with Huawei or a subsidiary of Huawei. …not proceed or agree to participate. At this time, UNL is declining to allow participation in most of these programs.

…alert your Department Dean/Chair/Supervisor

…contact Research Compliance Services (RCS) to discuss conflict of interest or export control concerns    
-The ECCP keeps up to date on any developments in federal guidelines and regulations around foreign talent programs  
…have travel reimbursed or sponsored by a foreign entity, individual or government …contact Research Compliance Services to discuss conflict of interest or export control concerns

…comply with the UNL travel policy, submit the trip to Concur, and complete an international travel checklist via NuRamp if requested

…disclose the relationship in your Interest and Outside Activity Reporting Form  
-The ECCP reviews each international travel checklist and performs necessary screenings and follow up

– RCS has laptops available for researchers to borrow for UNL related international travel.

-The COI coordinator reviews and screens all disclosures, international entities, and works with investigators to complete any necessary reporting to sponsors  
…have a foreign entity propose an institutional partnership with UNL or a consulting relationship with you …disclose the relationship in your Interest and Outside Activity Reporting Form

…contact Research Compliance Services to discuss conflict of interest or export control concerns  
-The ECCP works closely with Global Engagement to support the mission of connecting Nebraska to the world by reviewing collaborations and helping to streamline the development of international relationships

-The ECCP can provide screenings as appropriate for purchases and/or shipments of materials and equipment  
…have an active or proposed position with, or have been provided with funding by, a foreign institution …disclose the relationship in your Interest and Outside Activity Reporting Form  

…disclose the relationship to the Office of Sponsored Programs

…contact the Export Control Compliance Program to perform a review  
-The ECCP works closely with sponsored programs, NUtech, IBC, IRB, and COI areas to screen, review, and approve international relationships or work  

-The ECCP can provide screenings as appropriate for purchases and/or shipments of materials and equipment  
…have funding from DOE or DOD …contact the Export Control Compliance Program prior to starting any international collaboration, related to the research or otherwise.   -DOE and DOD have specific clauses that may limit international collaboration. The ECCP provides support to sponsored programs to identify and negotiate such clauses and works with the PI to develop an appropriate management strategy  
…have ownership interest in a foreign company …disclose the relationship in your COI/COC Disclosure Form   -The COI coordinator reviews and screens foreign companies and/or relationships disclosed via the COI/COC Disclosure Form  
…have any active research on campus (funded or un-funded) …be sure to submit Interest and Outside Activity Reporting Form at least annually or within 30 days of a change   -The COI coordinator reviews all disclosures made on campus and screens any foreign companies, compensation, or other relationships disclosed via the COI/COC Disclosure Form

-The ECCP works with the UNLPD building access team as necessary to secure labs working on restricted research

-The ECCP works with IT as necessary to develop procedures to protect research data  
…want to host a visiting scholar, student, tour group, or other individual from a foreign entity …work with the Office of Global Strategies and the International Student and Scholar Office (ISSO) to complete any necessary pre-visit paperwork

…contact Research Compliance Services to discuss export control concerns and complete screenings of individuals or entities  
-The ECCP works with the International Student and Scholar Office (ISSO) to review H1B and J1 visa applications and works with faculty to ensure they are prepared to host an international student, scholar, or visitor

-The ECCP works with the UNLPD building access team as necessary to secure labs working on restricted research

-The ECCP works with IT as necessary to develop procedures to protect researcher data  
…have concerns or questions about a proposed collaboration or research project …contact the Export Control Compliance Program, the COI program, or the general Research Compliance Services office to discuss your concerns  
Contact Research Compliance Services at 472-6965
EC: exportcontrol@unl.edu
COI: UNLCOI@unl.edu