Researchers and institutions seeking federal funding must comply with bipartisan security requirements.
Threats to U.S.-funded scientific research and development come in many forms, including through unethical or even illegal behavior by researchers on behalf of foreign entities.
This behavior has been encouraged by so-called malign foreign talent recruitment programs that have been established by “foreign countries of concern,” such as the People’s Republic of China. The programs require members to, for example, import proprietary data, technology, or other intellectual property developed using U.S. funds to “further the military modernization goals or economic goals” of the foreign entity. In exchange for participation in the program, researchers may receive cash, paid institutional appointments, or speaking engagements at foreign universities in the country of concern.
The issue of foreign influence over research has been met with regulatory responses across the last two administrations in Washington, D.C. Both the first Trump Administration and the Biden Administration have urged federal funding agencies to condition the disbursement of federal funds on institutional and individual researcher compliance with a set of requirements aimed at protecting their research from foreign influence.
President Donald J. Trump first issued a presidential memorandum in 2021 that underscored the importance of securing the U.S. research enterprise from “foreign government interference and exploitation” by taking steps to “protect intellectual capital, discourage research misappropriation, and ensure responsible management of United States taxpayer dollars.”
The Trump memorandum required federal funding agency heads to issue policies that require grant applicants to make disclosures in their applications and participate in “institutional research security programs” to be eligible for federal funding.
Building on the Trump Administration’s efforts, the Biden White House issued implementation guidance in 2022 to guide agencies on how to act on the Trump memorandum’s requirements in their forthcoming policies.
The Biden Administration’s implementation guidance—which remains in effect in the second Trump Administration—outlines the standardized disclosure requirements that funding agencies must impose on researchers seeking grant funding. Senior personnel running a proposed research study must disclose information about foreign connections in their grant applications, such as their organizational affiliations and employment, involvement in foreign talent recruitment programs, and any foreign sources of funding they have received or are receiving.
The implementation guidance also elaborates on the programs and procedures that institutions must certify that they have established.
Agencies must require, for instance, that institutions that receive federal funds establish cybersecurity programs and procedures. These programs need to include trainings that focus on recognizing and responding to cybersecurity threats and mechanisms that both limit access to internal systems by unauthorized users and monitor the transfer of sensitive information.
Institutions must also create a foreign travel security program that includes policies on how faculty and staff who are traveling internationally for teaching commitments, conferences, or research purposes must prepare. Prospective travelers should have to disclose their international commitments to the institution for authorization, have access to security protections for their electronic devices, and engage in safety briefings on keeping their research data protected.
Under the Biden guidance, agencies have to require institutions to establish a general research security training program for its researchers. The training is supposed to focus on how to identify research security threats and respond to them.
When necessary, funding agencies must also require that institutions that are conducting research subject to export control regulations—restrictions on the international transfer of certain materials such as software or technical information—train researchers on how to comply with these regulations.
Following the Biden Administration’s efforts to clarify the requirements in President Trump’s memorandum, the second Trump Administration has indicated its intent to increase enforcement of the requirements.
In April 2025, President Trump issued an executive order to promote the enforcement of a section of the Higher Education Act of 1965 which “requires institutions of higher education to report significant sources of foreign funding.” In this directive, President Trump argues that the Higher Education Act has not been “robustly enforced.” He encourages the Secretary of Education to work with other agencies, including the U.S. Department of Justice, to ensure that institutions make these disclosures when seeking federal funding and to hold them accountable when they are not.
As recent Administrations have sought to strengthen research security obligations, members of the scientific community have raised concerns about pursuing similar efforts through legislation. The SAFE Research Act, a bill that was to be incorporated into a larger bill defining the U.S. Department of Defense’s budget for fiscal year 2026, was recently removed following pushback from academic associations.
Research advocates argued that, as written, the bill would have prevented researchers seeking federal funds from having nearly any agreement with a Chinese university, including “every single research agreement, every study abroad program, every language program, every professional conference, and every campus facility that a U.S. university might have in partnership with another institution abroad.”
Restricting these connections would, according to one professional association, “chill collaboration, unfairly impact researchers, and undermine America’s competitive edge in science and technology.” In addition, a letter signed by faculty at 210 institutions argued that the statute could be unfairly enforced against U.S. researchers of Chinese descent. The bill was ultimately removed from the budget law.
Activists have also criticized a recent effort by Trump Administration officials that ordered federal agencies to scrutinize connections between U.S. researchers participating in federally funded projects and their foreign collaborators. One scientist called the move a “classic hallmark of authoritarianism,” rather than a safety measure.
Executive action targeting federal funding for research and higher education has remained in the spotlight since President Trump took office last January. The Administration has already used research security measures as a tool to influence U.S. researchers and their institutions for other policy objections. Ultimately, as the government struggles to protect its competitive edge while safeguarding national security interests, it remains to be seen how security requirements will influence the U.S. research enterprise across future administrations.