Maligned Foreign Talent Recruitment Programs and Federal Grant Compliance

Why This Matters

Federal agencies—including NSF, NIH, DOE, and DOD—require institutions to monitor and report participation in Foreign Talent Recruitment Programs (FTRPs) to protect U.S. research integrity and national security. These requirements apply to Principal Investigators (PIs), senior/key personnel, and others substantively involved in federally funded research.

Prohibition

Participation in malign foreign talent recruitment programs (MFTRPs) is prohibited. Institutions must ensure that individuals involved in federal awards are not participating in such programs and have disclosed relevant foreign affiliations and activities. Your disclosure and cooperation are expected.

What Is a Foreign Talent Recruitment Program?

A Foreign Talent Recruitment Program is any effort by a foreign government or institution to recruit researchers through incentives such as:
– Cash or research funding
– Travel support
– Honorific titles or appointments
– Career advancement opportunities

Programs are considered malign if they:
– Restrict the researcher’s ability to terminate the agreement
– Require recruitment of others
– Involve unauthorized transfer of intellectual property or data
– Establish foreign labs or companies in violation of federal award terms

Who Must Comply?

Compliance applies to:
– PIs and Co-PIs
– Senior/key personnel
– Individuals substantively involved in federally funded projects

These individuals must:
– Disclose participation in any FTRPs to EWU and/or sponsor
– Certify non-participation in malign programs
– Provide documentation of foreign affiliations, contracts, and appointments (can be through grant forms)

EWU OGRD Compliance Process

To meet federal requirements, EWU’s Office of Grant and Research Development (OGRD) requires all covered individuals to complete a Foreign Talent Recruitment Program Disclosure Questionnaire. This helps us assess risk and ensure institutional compliance.

If you are involved in a federally funded project, you must:
1. Complete the disclosure form–currently available here.
2. Submit supporting documentation if applicable.
3. Certify your non-participation in malign FTRPs.

Contact Information

If you have any questions or need assistance regarding Foreign Talent Recruitment Program compliance, please do not hesitate to contact us. We welcome your inquiries and are here to support you.

Email: ogrd@ewu.edu
Phone: 509-359-6567