In this video, we discuss the importance of international collaboration and performing appropriate due diligence for research security purposes.
Research Security Essentials: International Collaboration
Description of the video:
Hello, and welcome to the Research Security Essentials series from the Indiana University Research Security Office. In this video, we'll talk about the importance of international academic and research collaboration and how you can continue that important work while being cognizant of emerging threats and changing expectations and requirements from state and federal government and funding agencies related to research security. Indiana University has long been a leader in academic and research engagement internationally. Further, a core principle of the IU 2030 strategic plan is to create a welcoming environment of mutual respect where all students, faculty, and staff from every corner of the world are embraced as Hoosiers. Meanwhile, over the last several years, federal and state officials, independent science advisory groups, law enforcement, and others have signaled significant and increasing concerns surrounding the security of research and development at institutions of higher education in the United States. In light of these concerns, in 2021, the White House released National Security Presidential Memorandum 33, or NSBM 33, directing strengthened protections for federally funded research and development against foreign government interference and exploitation. NSBM 33 emphasized that the open and collaborative nature of the United States R&D enterprise underpins America's innovation, science and technology leadership, economic competitiveness, and national security. In response to NSBM-33 and related government directives, federal funding agencies, like the National Science Foundation, are conducting research security risk assessments prior to making awards and are also placing limits on the international activities of senior and key personnel. Additionally, the U.S. government continues to add individuals, institutions, and entities outside the U.S. to sanctions and other lists, each with its own unique ramifications. Researchers at IU engage internationally in a number of ways, including collaborating on publications or research with collaborators at international institutions, hosting visiting scholars, leading formal engagement agreements between IU and international institutions, and, of course, by educating and researching alongside the thousands of international students who call IU home. There are very real threats posed by state actors who wish to misappropriate the R&D carried out at IU. The Research Security Office was created by IU Research to protect the research environment from those threats. RSO is a service unit existing to serve IU's research community in navigating threats, related regulatory compliance, and ensuring the success of ongoing international scientific collaboration. In short, international collaboration is as vital now as it has ever been. But performing due diligence before international engagement is equally as important. The U.S. government and the state of Indiana have enacted specific restrictions related to the governments of and entities based in several countries. We'll call these foreign countries of concern or FCOC. They are China, Iran, North Korea, Russia, Cuba, and Venezuela. Contact the RSO prior to international engagement for assistance with due diligence, especially with an activity related to or entity based in an FCOC. When considering international engagement or collaboration, you should contact the RSO when planning on exporting a tangible item outside the U.S. For example, shipping, transporting, or hand-carrying. Anytime you plan on exporting intangible technology, like source code, outside the U.S. For example, emailing, accessing, or providing access information to such intangible information. Considering collaborating on research or publishing with colleagues at institutions outside the U.S., especially in an FCOC. You plan to host a visiting scholar whose home institution or employer is in an FCOC. Planning an institutional agreement between IU and an entity based outside the U.S. Considering an outside activity, like a visiting professorship or consulting role with an entity based outside the U.S. and traveling internationally for research or academic purposes, for example, presenting at a conference, especially to an FCOC. In these instances, RSO will assist you in conducting a risk analysis, utilizing U.S. government lists and other sources of information to ensure you and IU make informed decisions related to international collaboration. It is important to note that, while the U.S. government has placed some individuals and countries on sanctions lists for purposes of foreign policy, and some countries are comprehensively sanctioned, like Iran, Cuba, and North Korea, making it more difficult to lawfully engage. Research security primarily revolves around the risk posed by entities, institutions, and foreign governments. IU is committed to non-discrimination. Analysis of international collaboration should never be based on an individual's national origin. Now, let's go over what we've learned with some hypotheticals. Hi, RSO. I'm Dr. H, an IU faculty member. I mentored a Ph.D. student, Sarah, who graduated from IU and now works as an assistant professor at the Institute of High Energy Physics in Russia. I conduct fundamental research funded by the National Science Foundation related to physics and quantum computing. I want to collaborate with Sarah. Does this pose any research security concerns? Hi, Dr. H. Thank you for reaching out to the RSO. Even though you conduct fundamental research, the results of which are freely and openly published, there are some concerns here. First, we conducted a restricted party screening, and it revealed that Sarah's institution is heavily sanctioned by the U.S. Department of Commerce on its Bureau of Industry and Security Entity list. This means that it is illegal to export virtually any item, technology, etc. to Sarah or her institution without a license from the U.S. government, which will be denied. Second, the U.S. Department of Defense maintains a list called the Section 1286 list of institutions known to engage in illicit technology transfer. DOD advises caution for any researcher engaging with an institution on this list. The Institute of High Energy Physics is on this list. Finally, NSF is now conducting in-depth research security risk assessments for proposals. Their initial focus area is quantum computing. Engaging with Sarah now that she works at a sanctioned institution will likely jeopardize your funding opportunities. Hi, I'm Rory, a research scientist at IU. I have been asked to serve as a visiting scholar at a university in China. I've talked to my supervisor, and they said I should reach out to the RSO to discuss this potential outside activity. Are there any research security concerns here? I am sending over a copy of the contract I was asked to sign. It says I must recruit trainees into the same program and that I cannot terminate the contract. I thought that was odd. Rory, thanks for reaching out to the RSO. This proposed outside activity would violate IU policy, Indiana Executive Order 25-64, and would preclude you from serving on federal awards. This is because the activity is sponsored by an institution based in an FCOC and because of the unfavorable terms in the proposed contract. I'm glad you reached out. The RSO is here to consult on any international engagement, but when considering engagement with entities based in an FCOC, discussing with us first is vital. We will help you navigate the applicable state and federal requirements. As you can see, in today's evolving threat and regulatory environment, determining allowability or advisability of certain international collaborations and engagements is nuanced. The RSO team stands ready to assist you as a partner in performing appropriate due diligence and navigating governmental requirements. Together, we can ensure the important work of international academic and research collaboration continues, all while protecting you and the IU research environment. To discuss potential international collaboration or engagement or any other research security-related matters, please reach out to us at rsohelp at iu.edu. Thank you for watching this installment of Research Security Essentials from the Indiana University Research Security Office.