Researchers and institutions seeking federal funding must comply with bipartisan security requirements.<\/p>\n
Threats to U.S.-funded scientific research and development come<\/a> in many forms, including through unethical or even illegal behavior by researchers on behalf of foreign entities.<\/p>\n This behavior has been encouraged by so-called malign foreign talent recruitment programs that have been established by \u201cforeign countries of concern,\u201d such as the People\u2019s Republic of China. The programs require<\/a> members to, for example, import proprietary data, technology, or other intellectual property developed using U.S. funds to \u201cfurther the military modernization goals or economic goals\u201d of the foreign entity. In exchange for participation in the program, researchers may receive<\/a> cash, paid institutional appointments, or speaking engagements at foreign universities in the country of concern.<\/p>\n The issue of foreign influence over research has been met<\/a> with regulatory responses across the last two administrations in Washington, D.C. Both the first Trump Administration and the Biden Administration have<\/a> urged<\/a> 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.<\/p>\n President Donald J. Trump first issued a presidential memorandum<\/a> in 2021 that underscored the importance of securing the U.S. research enterprise from \u201cforeign government interference and exploitation\u201d by taking steps to \u201cprotect intellectual capital, discourage research misappropriation, and ensure responsible management of United States taxpayer dollars.\u201d<\/p>\n The Trump memorandum required<\/a> federal funding agency heads to issue policies that require grant applicants to make disclosures in their applications and participate in \u201cinstitutional research security programs\u201d to be eligible for federal funding.<\/p>\n Building on the Trump Administration\u2019s efforts, the Biden White House issued implementation guidance<\/a> in 2022 to guide agencies on how to act on the Trump memorandum\u2019s requirements in their forthcoming policies.<\/p>\n The Biden Administration\u2019s implementation guidance\u2014which remains in effect in the second Trump Administration\u2014outlines<\/a> the standardized disclosure requirements that funding agencies must impose on researchers seeking grant funding. Senior personnel running<\/a> 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.<\/p>\n The implementation guidance also elaborates<\/a> on the programs and procedures that institutions must certify that they have established.<\/p>\n Agencies must require, for instance, that institutions that receive federal funds establish<\/a> cybersecurity programs and procedures. These programs need to include<\/a> 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.<\/p>\n Institutions must also create<\/a> 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<\/a> 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.<\/p>\n Under the Biden guidance, agencies have to require<\/a> institutions to establish a general research security training program for its researchers. The training is supposed to focus<\/a> on how to identify research security threats and respond to them.<\/p>\n When necessary, funding agencies must also require that institutions that are conducting<\/a> research subject to export control regulations\u2014restrictions on the international transfer of certain materials such as software or technical information\u2014train<\/a> researchers on how to comply with these regulations.<\/p>\n Following the Biden Administration\u2019s efforts to clarify the requirements in President Trump\u2019s memorandum, the second Trump Administration has indicated its intent to increase enforcement of the requirements.<\/p>\n In April 2025, President Trump issued an executive order<\/a> to promote the enforcement of a section of the Higher Education Act of 1965<\/a> which \u201crequires institutions of higher education to report significant sources of foreign funding.\u201d In this directive, President Trump argues<\/a> that the Higher Education Act has not been \u201crobustly enforced.\u201d 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.<\/p>\n 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>, a bill that was to be incorporated into a larger bill<\/a> defining the U.S. Department of Defense\u2019s budget for fiscal year 2026, was recently removed following pushback from academic associations.<\/p>\n Research advocates argued<\/a> that, as written, the bill would have prevented researchers seeking federal funds from having nearly any agreement with a Chinese university, including \u201cevery 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.\u201d<\/p>\n Restricting these connections would<\/a>, according to one professional association, \u201cchill collaboration, unfairly impact researchers, and undermine America\u2019s competitive edge in science and technology.\u201d In addition, a letter<\/a> 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<\/a> from the budget law.<\/p>\n Activists have also criticized a recent effort by Trump Administration officials that ordered<\/a> federal agencies to scrutinize connections between U.S. researchers participating in federally funded projects and their foreign collaborators. One scientist called<\/a> the move a \u201cclassic hallmark of authoritarianism,\u201d rather than a safety measure.<\/p>\n