Research Security Reviews

Review the information below to determine if your international collaboration should be reviewed by the Penn State Research Security Program. You may request a review by completing this intake form. Response times may vary depending on the complexity of your proposed collaboration. If you are usure if your collaboration requires a review, please email research-security-orp@psu.edu.

What is a Research Security Review?

A Research Security Review is a process to evaluate international scholarly activities (such as collaborations, co-authorship, agreements, funding/support, data/material transfers) to identify and manage potential risks. The goal is to protect your research, the University, and U.S. interests, such as national security and economic competitiveness, from undue foreign influence, theft, or misuse.

Who Conducts Research Security Reviews?

Research security reviews are conducted by both U.S. federal funding agencies and the University.

Federal agencies such as the National Science Foundation (NSF), National Institutes of Health (NIH), Department of Defense (DoD), and Department of Energy (DoE) and others review proposal information, disclosures, and publicly available data as part of their funding process. They look for potential concerns, including:

  • Ties to a foreign government or military.
  • Evidence of research supporting foreign military development.
  • Participation in certain Foreign Talent Recruitment Programs.
  • Connections with restricted entities or organizations subject to U.S. sanctions.

Important

If a funding agency contacts you directly about research security concerns, do not respond alone. Notify the University’s Research Security Program (RSP) or the Office of Sponsored Programs office immediately. These offices can help ensure your response is accurate, complete, and compliant.

How the University Assesses Collaborators

You are encouraged to perform due diligence on potential collaborators, especially those in foreign countries of concern (e.g., China, Russia, Iran, North Korea, based on current federal guidance). The University’s Research Security Program (RSP) will assist you by conducting checks such as:

  • Restricted Party Screening: We check if your proposed international collaborators or their institutions appear on U.S. Federal government restricted or sanctioned party lists (e.g., Entity List, SDN List). Collaborating with restricted parties may be prohibited or require a license.
  • Export Control Regulations: We review whether your research activities involve technologies, software, data, or items subject to U.S. Export Control regulations. These rules govern the transfer of controlled items internationally or to foreign nationals within the U.S. (known as a ‘deemed export’). An export license may be required.
  • Malign Foreign Talent Recruitment Programs (MFTRPs): We help assess if a proposed collaboration might constitute involvement with an MFTRP. Participation or potential participation in certain foreign government-sponsored talent programs will affect your eligibility for federal funding. Even seemingly standard academic activities (like compensated travel for collaboration in “countries of concern”) could potentially be considered an MFTRP under current federal definitions. Disclosure is key.

Based on these checks, the RSP can provide guidance to help ensure your collaborations comply with relevant laws and regulations, including Export Controls and research security requirements.

What Happens if Risks are Found?

Identifying a potential risk doesn’t automatically mean the collaboration cannot proceed. Often, the RSP will work with you and the funding agency (if applicable) to develop a Risk Mitigation Plan when required. This plan outlines steps to manage the identified risks, often allowing the research to move forward securely and compliantly.

Your Role: Timely Disclosures and Proactive Engagement

Your active participation is crucial for ensuring research security compliance. Your primary responsibilities are:

Timely, accurate, and complete disclosure: You must disclose all foreign affiliations, appointments, funding (financial and in-kind), travel, and potential talent program participation. This is done via the following:

Proactive Engagement: Contact the University’s Research Security Program early in the planning stages of any international engagement before finalizing plans or agreements.

The Research Security Program is your primary resource for navigating these complex requirements, getting clarification, and ensuring your collaborations are compliant and secure. Full disclosure protects you, your research, and the University.

Office for Research Protections

Address

200 Innovation Blvd.
Suite 110
University Park, PA 16802

The Office for Research Protections (ORP) ensures that research at the University is conducted in accordance with federal, state, and local regulations and guidelines that protect human participants, animals, students, and personnel involved with research.

Contact

Phone: (814) 865-1775

Email: orp@psu.edu