Research Security: Foreign Influence & Malign Foreign Talent Programs

South Dakota Mines is committed to fostering responsible international collaboration while protecting the integrity of federally funded research. As national concerns about undue foreign influence grow, federal agencies have strengthened disclosure, reporting, and training requirements for researchers.

Compliance and Guidance

South Dakota Mines values international collaboration and the global exchange of ideas that strengthen scientific discovery. At the same time, the U.S. government has increasingly highlighted national-security risks related to undue foreign influence on federally funded research.

To protect researchers and safeguard federal investments, South Dakota Mines supports a comprehensive research-security program that emphasizes transparency, responsible collaboration, and adherence to federal disclosure requirements.

Federal agencies require award recipients to disclose certain foreign relationships, outside activities, and potential conflicts of interest or commitment. These requirements exist to ensure:

  • Integrity of the U.S. research enterprise
  • Protection of intellectual property and controlled information
  • Transparent and ethical collaboration with international partners
  • Compliance with sponsor-specific conflict of interest and commitment rules

Researchers at South Dakota Mines must disclose relevant foreign engagements and outside activities as required under SDSMT COI Policy 4-20 (Conflicts of Interest) and under the disclosure rules of federal funding agencies.

Under federal guidance, Foreign Government-Sponsored Talent Recruitment Programs are defined as programs organized, managed, or funded by a foreign government or foreign entity seeking to recruit scientists, researchers, or students. Occasionally programs may include problematic terms that conflict with U.S. research norms and award conditions. Federal agencies require researchers to disclose participation in any foreign talent recruitment program through documents such as:

  • Biographical sketches (biosketch)
  • Current and pending/other support forms
  • COI disclosures, when applicable

Disclosure requirements vary by agency and sponsor; South Dakota Mines researchers must follow the rules of each federal sponsor.

Federal Prohibition (CHIPS & Science Act of 2022)

Federal agencies are prohibited from issuing new research awards to proposals in which a covered individual (PI, co-PI, senior/key personnel, or equivalent) participates in a Malign Foreign Talent Recruitment Program (MFTRP). MFTRPs involve recruitment programs sponsored by or based in a foreign country of concern, including:

  • People’s Republic of China
  • Democratic People’s Republic of Korea (North Korea)
  • Russian Federation
  • Islamic Republic of Iran
  • Additional countries designated by the U.S. Department of State

MFTRPs typically involve compensation – financial or in-kind – in exchange for problematic obligations such as:

Examples of problematic expectations:

  • Unauthorized transfer of IP, materials, or non-public federally funded research data
  • Establishing labs, accepting positions, or forming companies abroad in violation of U.S. award terms
  • Requirements to recruit researchers into foreign programs
  • Limitations on terminating participation
  • Requirements to apply for foreign government funding as a condition of participation
  • Requirements to hide, omit, or not disclose the engagement to South Dakota Mines or U.S. funding agencies

All covered individuals on federally funded proposals or awards must:

  1. Disclose participation in foreign talent recruitment programs in federal biosketches and/or current & pending/other support, depending on the sponsor.
  2. Certify non-participation in MFTRPs when required by federal agencies—either at proposal, JIT, or annually for the duration of the award.
  3. Report outside activities and foreign engagements as required under SDBOR COI policy and sponsor regulations.

South Dakota Mines researchers must follow the disclosure rules issued by each federal agency and by SDBOR.

To comply with federal research-security requirements, all South Dakota Mines faculty, researchers, staff, students, and personnel involved in research must complete:

1. CITI “Research Security Training (Combined)” Course

This course covers:

  • Research security fundamentals
  • Disclosure requirements
  • Foreign influence and research integrity
  • Best practices for safeguarding data, IP, and federally funded research

Training Frequency:

  • Required prior to participating in research
  • Must be completed at least once every two years

2. Malign Foreign Talent Recruitment Program (MFTRP) Annual Certification

After completing the CITI Research Security Training, researchers must log into the South Dakota Mines Experience Portal, navigate to the Research card, and complete the MFTRP certification. This certification confirms compliance with the CHIPS & Science Act and federal sponsor requirements.

All researchers are responsible for:

  • Fully disclosing outside activities, affiliations, or foreign relationships as required by sponsor rules
  • Completing required research-security training
  • Certifying non-participation in MFTRPs
  • Reporting changes in activities within sponsor-required timelines
  • Following all South Dakota Mines, SDBOR, and federal requirements related to research security