Foreign Talent Recruitment Programs (FTRPs) and Malign FTRPs

Foreign Talent Recruitment Programs

A Foreign Talent Recruitment Program (FTRP) is an effort organized, managed, or funded by a foreign government or foreign entity to recruit science and technology professionals or students in targeted fields. Many of these programs utilize grants and research fellowships to encourage researchers to relocate to the foreign country as a means of growing the pool of talent in the respective field. 

Malign Foreign Talent Recruitment Programs

Participation in certain FTRPs, called malign foreign talent recruitment programs (“MFTRP”), may raise research security concerns. The Rockefeller University prohibits any personnel who contributes in a substantive, meaningful way to the scientific development or execution of a research and development project at the University from participating in any malign foreign talent recruitment programs, consistent with the CHIPS and Science Act of 2022 and applicable regulations. Such personnel are required to complete certification forms regarding their non-participation in MFTRPs, using forms provided by federal sponsors (e.g., NSF) or the University (for NIH). (See OSPA’s May 2, 2025 communication.)

For definitions of FTRP and MFTRP, see below.  

DEFINITIONS

A foreign talent recruitment program is (a) any program, position, or activity that (b) includes Compensation (c) 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, (d) to an individual, (e) whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.

Compensation, regardless of the amount, may be in the form of: 

  • cash;
  • in-kind compensation, including research funding, space, staff, and materials;
  • promised future compensation;
  • complimentary foreign travel;
  • things of non de minimis value;
  • honorific titles;
  • career advancement opportunities; or
  • other types of remuneration or consideration.

An FTRP does not include international collaboration activities (unless funded, organized, or managed by an MFTRP) as follows: 

  1. Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law;
  2. Participating in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law;
  3. Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student’s request; and 
  4. Engaging in the following international activities: 

a. Activities that are partly sponsored or otherwise supported by the United States such as serving as a government appointee to the board of a joint scientific fund (e.g., the U.S.- Israel Binational Industrial Research and Development Foundation); providing advice to or otherwise participating in international technical organizations, multilateral scientific organizations, and standards setting bodies (e.g., the International Telecommunications Union, Intergovernmental Panel on Climate Change, etc.); participating in a Fulbright Commission program funded in whole or in part by a host country government; or other routine international scientific exchanges and interactions, such as providing invited lectures or participating in international peer review panels;

b. Involvement in national or international academies or professional societies that produce publications in the open scientific literature that are not in conflict with the interests of the federal research agency (e.g., membership in the Pontifical Academy of Sciences or The Royal Society);

c. Taking a sabbatical, serving as a visiting scholar, or engaging in continuing education activities such as receiving a doctorate or professional certification at an institution of higher education (e.g., the University of Oxford, McGill University) that are not in conflict with the interests of the federal research agency;

d. Receiving awards for research and development which serve to enhance the prestige of the federal research agency (e.g., the Nobel Prize);

e. Other international activities determined appropriate by the federal research agency head or designee.

 

A Malign foreign talent recruitment program is an FTRP, involving Compensation (see definition above), by a Foreign Country of Concern or Foreign Entity of Concern (see definitions below), to an individual, in exchange for the individual—

(i)            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;

(ii)           being required to recruit trainees or researchers to enroll in such program, position, or activity;

(iii)          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;

(iv)          being unable to terminate the foreign talent recruitment program contract or agreement, except in extraordinary circumstances;

(v)           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;

(vi)          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; 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;

(vii)        being required to not disclose to the federal research agency or employing institution the participation of such individual in such program, position, or activity; or

(viii)       having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the federal research and development award.

Foreign Country of Concern or Foreign Entity of Concern are defined as:

  • Foreign Countries of Concern:  Foreign Countries of Concern are defined in accordance with federal law (42 U.S.C. § 19237(2)) and, as of April 22, 2025, mean the People’s Republic of China, the Democratic People’s Republic of Korea, the Russian Federation, and the Islamic Republic of Iran.
  • Foreign Entities of Concern include certain programs sponsored by, based in, or affiliated with a Foreign Country of Concern, whether or not directly sponsored by the Foreign Country of Concern.  Additionally, the U.S. Department of Defense has compiled a list of Congressionally-designated academic institutions and foreign talent recruitment programs whose programs are considered malign, as referenced in Section (B)(ii) and (B)(iii) below, at: https://basicresearch.defense.gov/Portals/61/Documents/Research%20Security/1286%20List.pdf?ver=nEagju7uAK3DCdfMt9yZGg%3D%3D.
  • The lists of Foreign Countries of Concern and Foreign Entities of Concern are subject to change, so please check for updates when you are certifying.