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One important objective of NSPM-33 is to standardize requirements and processes for disclosure of information related to potential conflicts of interest and commitments from participants in federally funded research projects. As federal agencies determine how they will implement NSPM-33 disclosure requirements, Sponsored Projects will create a webpage that summarizes the disclosure requirements from each federal funding agency.

With the goals of increasing accuracy and minimizing the burden of disclosures, NSPM-33 advises federal funding agencies to permit the submission of required disclosures via a digital persistent identifier (DPI) service, such as ORCID. University Libraries maintains information on that provides information about registering for a free ORCID account.

A foreign talent recruitment program is an effort organized, managed, or funded by a foreign government, or foreign government entity, to recruit science and technology professionals or students. Foreign talent recruitment programs typically include 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 to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.

Participation in a foreign talent recruitment program is generally not prohibited by U.S. federal agencies unless it is considered a Malign Foreign Talent Recruitment Program.

Malign Foreign Talent Recruitment Programs

In accordance with federal regulations, the University prohibits researchers working on federally-funded research and development awards from participating in foreign talent recruitment programs that meet the definition of a Malign Foreign Talent Recruitment Program (MFTRP). Please see the Sponsored Projects policy on Malign Foreign Talent Recruitment Programs for the definition of a MFTRP and information on disclosure requirements.

International Collaboration Activities that are not foreign talent recruitment programs

A foreign talent recruitment program does not include the following international collaboration activities, so long as the activity is not funded, organized, or managed by an academic institution or a foreign talent recruitment program on the lists developed under paragraphs (8) and (9) of Section 1286(c) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232):

1. Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law;
2. Participating in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law;
3. Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student's request; and
4. Engaging in the following international activities:
   1. Activities that are partly sponsored or otherwise supported by the United States such as serving as a government appointee to the board of a joint scientific fund (e.g., the U.S. Israel Binational Industrial Research and Development Foundation); providing advice to or otherwise participating in international technical organizations, multilateral scientific organizations, and standards setting bodies (e.g., the International Telecommunications Union, Intergovernmental Panel on Climate Change, etc.); participating in a Fulbright Commission program funded in whole or in part by a host country government; or other routine international scientific exchanges and interactions such as providing invited lectures or participating in international peer review panels.
   2. Involvement in national or international academies or professional societies that produce publications in the open scientific literature that are not in conflict with the interests of the federal research agency (e.g., membership in the Pontifical Academy of Sciences or The Royal Society).
   3. Taking a sabbatical, serving as a visiting scholar, or engaging in continuing education activities such as receiving a doctorate or professional certification at an institution of higher education (e.g., the University of Oxford, McGill University) that are not in conflict with the interests of the federal research agency.
   4. Receiving awards for research and development which serve to enhance the prestige of the federal research agency (e.g., the Nobel Prize).
   5. Other international activities determined appropriate by the federal research agency head or designee.

NSPM-33 identifies baseline safeguarding protocols and procedures for information systems used to store, transmit and conduct federally funded research and development. The Office of Information Security has conducted a cybersecurity assessment and determined that current protocols and procedures for computers and other endpoints under their control meet NSPM-33 requirements.

NSPM-33 requires covered research organizations to have an international travel policy that includes elements of prior approval and training. The University’s International Travel Policy requires travelers to request prior approval through an international travel authorization request. Upon approval, the University’s Export Control Officer provides travelers with information regarding electronic device and data security in addition to export and import guidance. The University has an which provides loaner laptops and encrypted flash drives for international travel. Laptops are wiped, reformatted and reimaged immediately upon return. Use of loaner laptops is voluntary for most destinations; however, it is mandatory for travel to countries deemed to be high cybersecurity risks.

The ·¬ÇÑÊÓƵ is committed to compliance with U.S. export control and economic sanctions laws and regulations. University employees, students and volunteers must comply with

1. All federal laws and regulations
2. NSHE Export Control and Economic Sanctions Policy (chapter 14)
3. Sponsored Project's Export Control and Economic Sanctions Compliance Policy

The University utilizes the web-based Collaborative Institutional Training Incentive (CITI) for trainings related to export control and economic sanctions.

The University currently requires all faculty and staff to complete on an annual basis.

When research security training is required, the University utilizes the web-based Collaborative Institutional Training Incentive (CITI). View the instructions for research security training through CITI.