AI for Privacy, Safety, and Security Academic Research Awards

AI for Privacy, Safety, and Security Academic Research Awards is sponsored by National Science Foundation (NSF). This program supports research and networks to improve oversight, evaluation, and accountability in AI governance, prioritizing public interest, equity, and transparency in high-impact sectors. It includes research on research security to safeguard the U.

Research Security | NSF - U.S. National Science Foundation Research Security at the National Science Foundation Office of the Chief of Research Security Strategy and Policy View image credit & caption On July 10, 2025, NSF issued an Important Notice (NSF IN-149) providing updates to NSF Research Security Policies, including: a research security training requirement, Malign Foreign Talent Recruitment Program annual certification requirement, prohibition on Confucius institutes and an updated FFDR reporting and submission timeline.

Those policies are effective as of Dec. 2, 2025 . Research security: What is it?

Research security focuses on strengthen protections of United States Government-supported Research and Development (R&D) against foreign government interference and exploitation. This includes safeguarding the research enterprise against the misappropriation of research and development to the detriment of national or economic security, related violations of research integrity and foreign government interference.

Research security at NSF: Why does it matter? Securing the nation's research enterprise is part of the mission of the U.S. National Science Foundation and is essential to the national defense.

NSF works closely on this effort with its funding agency counterparts and with the law enforcement and intelligence communities — consistently emphasizing the importance of balancing research security with international collaboration in science and engineering.

NSF has dedicated considerable effort and resources to working with the research community and its other partners to: Equip researchers with the information and tools necessary to ensure that their work is protected. Clarify security issues and mitigate risks. Foster transparency, disclosure and other practices that reflect the values of research integrity.

NSF's effort has led to ongoing initiatives aimed at clarifying proposal preparation and award administration requirements, as well as the issuance of new policies and directives in the proposal and award process. Case study 1: Failure to respond to an OIG subpoena related to foreign funding and affiliations An NSF-funded principal investigator is employed by a U.S. organization.

The PI does not disclose any information about foreign funding/affiliations in NSF proposals, even though that information is required by NSF's Proposal and Award Policies and Procedures Guide. On the OIG's recommendation, NSF suspends the PI's awards to the U.S. organization. The researcher, although represented by counsel, resigns from the U.S. organization, and leaves the United States, but fails to fully respond to the subpoena.

On the OIG's recommendation, NSF imposes a government-wide debarment on the researcher (including a bar on serving as a reviewer, adviser or consultant) for a fixed term.

This recommendation is in view of the researcher's failure to respond to the OIG's subpoena (for example, through court action contesting the subpoena or full production of documents) and in view of information indicating that the researcher failed to fully disclose current and pending support in proposals to NSF.

At the end of the debarment period, NSF will consider the decision to determine if an extension is necessary to protect the public interest. As the PI is no longer involved in the NSF-funded research, NSF lifts the suspension of the awards.

Outcome : While there were no formal proceedings instituted against the researcher in federal court, NSF took three types of actions — award suspension, debarment and lifting of award suspension — at different stages of the OIG's investigation. These actions were tailored to the risk to NSF in view of the information available at the time the action was taken.

Case study 2: Failure to report extended absences and to respond to an OIG subpoena Publicly available information indicates that, in succession over a brief period, the PI's proposal is funded, the PI is selected as a foreign talent plan participant, and the PI begins extended leave to visit family in a foreign country. The term of the extended leave corresponds to the time the PI is listed as having a foreign appointment.

During this same time, the PI also returns to the United States to serve as an NSF panelist. The PI does not disclose foreign support or appointments to NSF or to their U.S. organization. The OIG subpoenas the PI for information about employment outside of the U.S. organization.

The PI declines, citing restrictions by the PI's foreign employer. Based on an OIG recommendation, NSF suspends the award. The organization agrees to terminate, while also returning the funds received after the PI went on leave.

On the OIG's recommendation, NSF also imposes a bar on the PI serving as an NSF reviewer, adviser or consultant. Outcome : During the lifecycle of the OIG' s investigation, NSF and the organization took different actions to mitigate risk to NSF, including award suspension and termination, repayment of funds and imposition of a reviewer bar.

Case study 3: Grant fraud involving a foreign talent plan participant A professor at a U.S. organization founds a company that relies exclusively on federal grants to fund research, including NSF SBIR/STTR funding. The professor/founder also begins working as a paid researcher at a foreign organization.

Additional information developed by the Department of Justice and OIG indicates that the funded research had already been completed at the professor/founder's foreign organization. As the investigation develops, NSF, on the OIG's recommendations, suspends awards, terminates awards, withholds final payment and reduces an award amount. DOJ files a criminal complaint against the professor/founder.

Based on the OIG's recommendation, NSF imposes a government-wide suspension on the professor/founder and related companies. Evidence is presented at trial indicating that grant funds obtained would be used for research the professor/founder knew had already been done overseas. The professor/founder intended to use the grant funds for other company projects rather than for the projects for which the funds were requested.

To obstruct the investigation, the professor/founder submitted falsified timesheets to government investigators. Information, including a talent plan contract, becomes available at trial that the professor/founder is a foreign talent plan participant.

DOJ prosecution results in criminal conviction of the professor/founder of one count of conspiracy to defraud the United States, three counts of making false statements and one count of obstruction by falsification. Based on a recommendation by OIG after the professor/founder's conviction, NSF imposes government-wide debarment and a reviewer bar on the professor/founder and related company for a fixed period.

Outcome : During a multi-year investigation, NSF took several administrative actions well before filings in federal court, based on recommendations by the OIG. These included award suspensions, terminations, withholding the final payment/reduction of an award amount and government-wide suspensions. The investigation resulted in a criminal conviction.

Thereafter, on the OIG's recommendation, NSF imposed a government-wide debarment in view of the risk to NSF and the professor/founder's lack of present responsibility.

Case study 4: NSF and a science association find research security and integrity violations The scientific association investigation found that the researcher violated the association's peer review process by repeatedly sharing reviewer names and individual scores connected with paper submissions to the association.

Additionally, the researcher coerced a co-author to proceed with a manuscript submission to the association, despite the co-author's repeatedly expressed concerns about the correctness of the results reported in that manuscript. Lastly, the researcher was part of a talent recruitment plan, which is itself allowable.

However, the malign foreign government talent plan affiliation was not disclosed to NSF and there were terms in the talent plan contract that could be linked to both the nondisclosure issues and the concerning behaviors found by the association's investigation. The researcher has since resigned from the U.S. university and left the United States.

Learn more about NSF's research security goals NSF's research security goals seek to: Improve transparency and continue to clarify disclosure requirements. Coordinate with U.S. government interagency partners to harmonize disclosure information to the extent practicable. Communicate and build awareness with the scientific community.

Share knowledge and best practices. Mitigate risk through assessment and analysis to better understand the scale and scope of research security threats. SECURE Center and SECURE Analytics SECURE (Safeguarding the Entire Community in the U.S. Research Ecosystem) Program Safeguarding U.S. research security is paramount as some foreign entities continue to attempt to exploit American innovation unethically or even unlawfully.

The U.S. National Science Foundation announced a five-year $67 million investment in establishing the Safeguarding the Entire Community of the U.S. Research Ecosystem (SECURE) Center.

Read about the individual awards SECURE Center (University of Washington) SECURE Analytics (Texas A&M) Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO) Program Solicitation, NSF 23-613 RSI-ISAO Solicitation Webinar Recordings Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO) Solicitation Webinar (NSF 23-613) RSI-ISAO Solicitation Webinar Slides (PDF, 1.

77 MB) Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO) Solicitation Webinar (NSF 23-613) The CHIPS and Science Act of 2022 (Public Law No. 117-167, Title III, Subtitle D, Sec. 10338), requires the NSF Director to enter into an agreement with a “qualified independent organization” to establish the Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO).

This organization will empower members of the research community to address foreign interference issues, support a security-informed decision-making structure, provide government officials with situational awareness, and offer the research community access to USG expertise.

Importantly, the organization will offload some of the administrative workload from those it serves and empower them to utilize tools and other capabilities not typically available to them. The specific roles of the RSI-ISAO may be found in Section 10338 . The agency is actively working to establish the RSI-ISAO in accordance with the requirement and in an effort to strengthen efforts to secure the national research security ecosystem.

Dear Colleague Letter: A Request for Input on the Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization RSI-ISAO DCL Webinar Recordings Stakeholder Engagement on Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO) Stakeholder Engagement on Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO) RSI-ISAO Webinar Slides (PDF, 777.

01 KB) Research on Research Security Program (RoRS) Research on Research Security Program (RoRS) NSF's new RoRS program supports interdisciplinary, evidence-based research to enhance understanding of security risks, practices and policies to safeguard the U.S. research enterprise and foster a strong academic field in research security. Read the program description .

Research on Research Security Webinar Slides Research on Research Security program (RoRS) (PDF, 782. 97 KB) NSF hosted a webinar on April 30, 2025, to share information on the new program description for the Research on Research Security (RoRS) Program. Research-on-Research Security Workshop Report In 2023, NSF funded a workshop designed to bring a variety of stakeholders in research security together.

The aims of the workshop were to assess the current research security landscape and develop a portrait of the emerging field of research on research security, Specifically, the workshop brought together national and international experts, government officials, and industry leaders who have an interested in conducting or supporting research on research security.

The report of the workshop below identifies the findings related to the nature of the field of research on research security, key questions and challenges for the field to pursue, methodology and theoretical approaches related to research on research security, and the need for data on research security to advance the field. Research security: What is it? Research security at NSF: Why does it matter?

The SECURE Center (Safeguarding the Entire Community in the U.S. Research Ecosystem) Research on Research Security Program (RoRS) The benefits of international collaboration UPDATED: NSF Policies and Actions Trusted Research Using Safeguards and Transparency (TRUST) UPDATED: Research Security Training for the research community Foreign interference and risk mitigation UPDATED: Foreign Financial Disclosure Report (FFDR) UPDATED: Malign Foreign Talent Recruitment Program (MFTRP) How NSF addresses research security violations If you are a staff member from a Sponsored Research Office (SRO) or a member of a federal agency with a research security-related concern, and you would like input from the OCRSSP, please contact researchsecurity@nsf.

gov . The responsibility of securing the nation’s research falls to everyone in the research community, both at home and abroad. NSF is committed to safeguarding the integrity and security of science while also keeping fundamental research open and collaborative.

The agency seeks to address an age of new threats and challenges through close work with partners in academia, law enforcement, intelligence and other federal agencies. By fostering transparency, disclosure and other practices that reflect the values of research integrity, NSF is helping to lead the way in ensuring taxpayer-funded research remains secure.

NSF-supported organizations Federally funded organizations also have a role as stewards of that research — including training the next generation of researchers.

Organizations receiving federal funding should demonstrate robust leadership and oversight; establish and administer policies to promote transparency and guard against conflicts of interest and commitment; provide training and information on research security; ensure effective mechanisms for compliance with organizational policies; and implement processes to assess and manage potential risks associated with collaborations and data.

Protecting one's own research from bad actors benefits the entire scientific ecosystem — the individual researcher, community, nation and world. Ultimately, research security is about ethical behavior, regardless of background or origin.

Ethical behavior is foundational to the conduct of research, and it can only be achieved when everyone can collaborate in an open environment, shielded from the threats of dishonest and unethical behavior. The benefits of international collaboration NSF welcomes and encourages international collaboration and views it as essential to pursuing the frontiers of science.

The agency has a long history of successful, open research collaborations with nations around the world and strongly maintains that scientific research benefits immensely from international cooperation. The benefits of principled international collaboration include: Enabling cutting-edge research that no nation can achieve alone. Training a robust science and engineering workforce capable of solving global problems.

Allowing for significant contributions from international students and scholars to the U.S. research enterprise. Strengthening scientific and diplomatic relations. Leveraging resources, including funding, expertise and facilities.

Principled international collaboration is critical to success, but improper foreign influence is a threat to international collaboration in the science and technology enterprise. It is important to distinguish the difference.

Learn about NSF's involvement in international research security efforts Balancing research security while maintaining open and collaborative international partnerships is vitally important to the global research ecosystem. NSF is actively involved in fostering international dialogue on how best to mitigate risks from bad actors that threaten the balance of secure research and trusted relationships in the global research community.

NSF makes significant contributions in this area as a key U.S. government representative on the Organisation for Economic Co-operation and Development (OECD) G-7 Working Group on the Security and Integrity of the Global Research Ecosystem, which was established to develop principles, best practices and a virtual academy and toolkit on issues relevant to research security and integrity.

NSF’s Office of International Science and Engineering NSF encourages U.S. scientists and engineers to enhance their research and education programs through international collaboration. OISE is dedicated to promoting engagement strategies and managing internationally focused programs and partnerships.

To achieve its goals, NSF has worked diligently to put measures in place that strengthen research security and integrity for the federal funded research community and for NSF staff. Actions include: Emphasizing compliance with disclosure rules in NSF's Proposal and Award Policies and Procedures Guide (PAPPG) both for NSF staff and the institutions and researchers funded by NSF.

On November 24, 2025, NSF issued an Important Notice providing Updates to NSF Research Security Policies, including: a research security training requirement, Malign Foreign Talent Recruitment Program annual certification requirement, prohibition on Confucius institutes and an updated FFDR reporting and submission timeline. Requiring all NSF personnel to be a U.S. citizen or in the process of becoming a citizen.

Requiring each Institution of Higher Education (IHE) who receive NSF funding to submit a Foreign Financial Disclosure Report (FFDR) through research. gov . The data elements collected in FFDR are available to view here .

Barring NSF staff from participating in foreign talent recruitment programs. Requiring annual "Science and Security Training" for all NSF employees. Requiring all senior/key personnel to certify on pre-award disclosures and PI/co-PIs to certify on post-award disclosures that they are not party to a Malign Foreign Talent Recruitment Program.

Prohibiting NSF from awarding funds to an IHE that maintains a contract or agreement between the institution and a Confucius Institute. Centralizing a process to assess Dual Use Research of Concern (DURC) to ensure more rigorous and consistent identification, assessment and oversight of DURC issues. Download a high-resolution version of this image (PNG, 0.

1MB) TRUST: Trusted Research Using Safeguards and Transparency Developed with the Foundation’s core science mission as a guide, the TRUST framework will guide the agency in assessing grant proposals for potential national security risks. This new policy will help safeguard U.S. taxpayer investments in research and innovation while strengthening international collaboration. The TRUST framework includes three branches.

The first focuses on assessing active appointments, positions, and research support, while the second focuses on identifying instances of noncompliance with disclosure requirements. The third branch — the inclusion of potential foreseeable national security considerations — represents a significant new effort for NSF.

The framework is designed to avoid curtailing beneficial research activities due to institutions or individuals in the community being overly cautious, protect the agency's core values of fairness and due process and maintain open lines of communication with the research community. The TRUST framework will be rolled out in a phased approach with a pilot focused on quantum-related projects set to launch in Fiscal Year 2025.

U.S. Bureau of Industry and Security Entity List Annex of Executive Order (EO) 14032 or superseding EOs Sec. 1260H of the National Defense Authorization Act (NDAA) for FY2021 Sec. 1286 of the NDAA for FY2019 , as amended NSF has established a dedicated email address for comments and questions about TRUST: TRUST@nsf.

gov .

Trusted Research Using Safeguards and Transparency (TRUST) Process Overview Webinar Research security actions Click on the items below to learn more about NSF's research security actions: JASON studies and resources NSF's overall research security activities respond to the JASON report, " Fundamental Research Security ," which was commissioned by NSF and published in December 2019, as well as subsequent legislation passed by Congress.

Since the report was published, NSF has worked to expand capabilities and competencies to protect the U.S. science and engineering enterprise through its research security strategy and policy activities.

Actions aimed at securing U.S. federally funded research In Fiscal Year 2021, NSF funded a JASON study on cybersecurity at NSF's major research facilities; in response to the JASON recommendations, NSF is developing new guidance for these research facilities and strengthening its major facility oversight in this area.

In January 2022, the National Science and Technology Council issued "Guidance for National Security Presidential Memorandum 33 (NSPM-33) on National Security Strategy for United States Government-Supported Research and Development." NSF commissioned a JASON study in FY 2022 to provide guidance on the establishment of a Research on Research Security funding program that is expected to begin in FY 2023.

Specific activities for FY 2023 include the following: NSF is working together with other federal research agencies to establish uniform mechanisms for research investigators to provide agencies with consistent information on their appointments, activities and sources of financial support; many of these mechanisms will be made available to the community during FY 2023.

NSF will establish a Research on Research Security funding program in FY 2023 using guidance from a JASON FY 2022 study. NSF is seeking U.S. federal agency and nonprofit organization partners to collaborate on this program.

NSF has established new analytic capabilities to proactively identify conflicts of commitment, vulnerabilities of pre-publication research, and risks to the merit review system, and has published a System of Records Notice that will enable NSF to begin utilizing those capabilities in FY 2022 and FY 2023.

To ensure clear understanding of research security issues, NSF disclosure requirements and the tenets of beneficial international collaboration, NSF has developed training resources for staff that will continue to be refined in FY 2023.

As previously discussed, in Training for the research community , through a partnership with the federal government interagency community, NSF has issued a solicitation to develop training resources for the research community, which will be funded in early FY 2023.

Federal actions governing NSF research security policies The " CHIPS and Science Act of 2022 " is a historic investment to increase production of American-made semiconductors, tackle supply chain vulnerabilities to make more goods in the United States, revitalize U.S. scientific research and technological leadership, and strengthen the nation's economic and national security at home and abroad.

The act includes significant investments and protections for research and development with specific guidance to NSF to do the following: Empower NSF research security: The act requires NSF to maintain a Research Security and Policy Office to identify potential security risks.

Train researchers on best practices and prohibit federal employees and university researchers from participating in malign foreign talent recruitment programs: The act requires covered individuals seeking funding from federal research agencies to complete annual training on research security.

Create a research security and integrity information-sharing organization : The act requires the establishment of an organization that would serve as a clearinghouse for information that helps institutions and researchers identify improper and illegal efforts that compromise research security.

Ensure transparency: The act requires universities applying for NSF funds to disclose agreements and gifts from China and other "foreign countries of concern." Also prohibits NSF funding from going to universities with Confucius Institutes. The National Security Presidential Memorandum – 33 (NSPM-33) was signed on January 14, 2021.

NSPM-33 directs federal funding agencies to strengthen protections of U.S. government-supported research and development against foreign government interference and exploitation. NSPM-33 seeks to clarify and simplify how researchers disclose information to the federal government.

Specifically, Section 4(g) of NSPM-33 directs that “heads of funding agencies shall require that research institutions receiving Federal science and engineering support in excess of 50 million dollars per year certify to the funding agency that the institution has established and operates a research security program.

As such, “the federal government” is tasked with “providing standardized technical assistance to support development of training content and programmatic guidelines, tools, and best practices to be made available to organizations for incorporation into research security programs at their discretion. ” The training modules in development under the direction of NSF are examples of best practices in action.

NSF is taking essential steps toward mitigating foreign government risks and threats to U.S. government-funded research and working to fulfill government mandates to protect federally funded research as outlined in the NSPM-33 and the CHIPS and Science Act of 2022.

Training and education in research security best practices Click on the items below to learn more about training offered by NSF: Training for the research community While institutions/organizations are welcome to provide trainings beyond those developed by the U.S. Government, NSF, in partnership the National Institutes of Health (NIH), the Department of Energy (DOE) and the Department of Defense (DOD), as well as the NSF SECURE Center have developed a suite of online research security training (RST) modules as a resource to support compliance.

The training modules cover a range of research security topics, including the importance of research security, disclosure requirements, promising practices for managing risk, the value of international collaboration, malign foreign talent recruitment programs, and foreign travel security. Condensed Module: The most recent training resource was developed and released in June 2025 by the SECURE Center.

The condensed training module (CTM) pulls from four training modules developed in collaboration with NSF, NIH, DOE, and DOD. The SECURE Center condensed and updated the expanded training to empower the research community. Designed to meet all the requirements in Section 10634 of the "CHIPS and Science Act of 2022" (42 U.S.C.

§ 19234), NSF, NIH, DOE, DOD and USDA recognize the CTM as satisfying their respective RST requirements for senior/key personnel. The condensed training module can be found here . Research security analytics guidelines In 2023, NSF published how it approaches research security data-related practices.

The guidelines include a breakdown of which agency personnel may conduct research security-related activities; what monitoring activities are allowed and with what resources they are conducted; how information will be validated to ensure accuracy; and how information may be shared within NSF and externally.

Foreign interference and risk mitigation NSF's goal is to maintain a vibrant science and engineering community that can participate in domestic and global collaborations. However, there are actors who try to take advantage of the openness of the research community and choose not to uphold the values of the science and engineering community.

Disclosure and transparency Senior/key personnel disclosures are provided in three distinct sections of an NSF proposal: Collaborator and Other Affiliations, the Biographical Sketch, and Current and Pending (Other) Support. Senior/key personnel must certify that the information provided is current, accurate, and complete, and that they are not a party to a malign foreign talent recruitment program.

A main issue related to foreign interference in NSF-funded research is the omission of information in senior/key personnel disclosures, including appointments, affiliations and current and pending (other) support from external funding sources. Transparency and disclosure are vital to NSF’s ability to properly assess risk. When information is deliberately omitted or concealed, the award-making process is compromised.

To assess the risk of foreign interference in institutions of higher education that carry out NSF-funded research, institutions of higher education are now required to submit post-award disclosures of financial support received from a foreign source associated with a foreign country of concern.

Learn more about proposal disclosure documents This information is used as follows: Collaborators and Other Affiliations are listed in a separate, single copy document and are used by NSF program staff to help manage reviewer selection and avoid conflicts of interest in the review process.

The Biographical Sketch is used by NSF program staff and external reviewers to assess how well qualified the individual, team or organization is to conduct the proposed activities.

The Current and Pending (Other) Support information is used by NSF program staff and external reviewers to assess the capacity of the individual to carry out the research as proposed, as well as to help identify any potential overlap or duplication with the project being proposed. Note, NSF treats the withholding of information as noncompliance with its disclosure requirements.

Foreign Financial Disclosure Report (FFDR) Overview: Foreign Financial Disclosure Report (FFDR) NSF has developed a reporting process (Foreign Financial Disclosure Report) for institutions of higher education that are direct recipients of NSF funding to disclose gifts and contracts received from a foreign country of concern. NSF is implementing the Foreign Financial Disclosure Report as mandated by the CHIPS and Science Act of 2022.

Guidance and Critical Dates for FFDR Preparers More information about the FFDR preparation and submission process can be found at the research. gov FFDR homepage . The data elements collected in FFDR are available to view here .

CHIPS and Science Act of 2022 Legislation In accordance with Section 10339B, Foreign Financial Support, of the CHIPS and Science Act of 2022 ( 42 U.S.C.

§ 19040 ), each institution of higher education that receives NSF funding must disclose annually, all "current financial support, the value of which is $50,000 or more, including gifts and contracts, received directly or indirectly from a foreign source" associated with a foreign country of concern. See Proposal & Award Policies & Procedures Guide (PAPPG) Chapter VII. D.

3 for additional information. On July 10, 2025, NSF issued an Important Notice providing updates to NSF research security policies, including an updated FFDR reporting and submission timeline. Malign Foreign Talent Recruitment Program (MFTRP) Malign Foreign Talent Recruitment Program(s) Malign Foreign Talent Recruitment Programs (MFTRPs) are a significant concern for safeguarding U.S. research and development (R&D).

Participation in these programs is generally associated with harmful behaviors by individuals entrusted with conducting R&D on behalf of the American people. Deception, misuse of federal funds, running duplicate labs, and recruitment on behalf of a foreign country of concern, among others, puts U.S. R&D at risk of undue foreign interference and unauthorized transfer of intellectual property.

These actions threaten the careers of talented U.S. researchers, the integrity and reliability of research, the public's trust in science, and U.S. national interests. Recognizing the risks MFTRPs pose, Congress has directed federal funding agencies to prohibit participation in these programs by organizations and researchers seeking or receiving Federal support.

The NSF Proposal and Awards Policies and Procedures Guide (PAPPG) follows the definition of MFTRPs set forth in the CHIPS and Science Act of 2022 and U.S. Office of Science and Technology Policy (OSTP) implementing guidelines. Malign foreign talent recruitment program.

The term "malign foreign talent recruitment program" means: Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration 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, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, 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