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OVERVIEW

In February 2020, the University of Utah Foreign Influence Task Force submitted its final report to President Ruth Watkins. According to the report, "[u]ndue foreign influence is defined as an influence by non-US persons or entities, including foreign governments, that seek to compromise U.S. national security and economic security or which results in loss, including by theft, of United States’ intellectual property or academic opportunities... 

Advancing research and discovery involves robust exchange of intellectual ideas and collaboration. These efforts must, simultaneously, uphold U.S. standards for research integrity and give due consideration to legitimate threats to national and economic security."

In addition to the University of Utah Foreign Influence Task Force's findings, federal funding agencies, policymakers, and law enforcement agencies have identified the following main concerns related to undue foreign influence: 

  1. Violations involving the peer review process
  2. Failure to disclose foreign resources:
    • Foreign employment
    • Foreign grant support that creates conflicts of interest and/or conflicts of commitment
    • Foreign research support:
      • Personnel (visiting scholar/student)
      • Office/Lab Space
      • Equipment
    • Foreign Talents Programs
    • Transfers of information, know-how, data, person-time
  3. Failure to disclose significant foreign financial Conflict of Interest:
    • Financial interests in foreign companies
    • Foreign patents that leverage US tax-payer funded work
  4. Compliance with Regulatory Requirements:
    • U.S. Export Control laws and regulations establish a set of requirements for the transfer of technology and data to foreign countries and/or foreign nationals in the U.S.
    • The Office of Foreign Assets Control (OFAC) restricts interactions with individuals or entities on the sanctions list.
    • The Centers for Disease Control and Prevention (CDC) and the Department of Agriculture (USDA) require permits for the importation of many biological materials.

DISCLOSURE REQUIREMENTS

How can I protect myself?
  • Update your financial disclosure now to ensure it accurately reports your foreign affiliations. You may report concerns to the University of Utah’s Office of General Counsel.
What do I need to disclose and how do I disclose?
  • According to the University's Individual Conflict of Interest Policy 1-006, investigators must disclose all forms of other support and financial interest, including support from foreign governments or other foreign entities, that reasonably appear to be related to their jobs or responsibilities to the University. Disclosure should be made on the Business Relationship Reporting (“BRR”) website. Revisions to this site will be released soon to allow for greater ease in disclosure. 
What should I do if I didn’t disclose previously?
  • File a disclosure now. If you have a concern, please contact the University of Utah’s Office of General Counsel or the Conflict of Interest Office for assistance.
Where can I learn more about undue foreign influence?
  • Contact the COI office to schedule an in-person training for your department.
  • Research Education will offer a course on Foreign Influence soon.

 

Examples of foreign affiliations requiring disclosure (please contact the COI Office if you have questions about disclosure):

  • Disclose this under the Employment tab in BRR.
  • Answer ‘yes’ to the question “Do you or your Family Members have employment outside of the University of Utah that would appear reasonably related to your professional responsibilities to the University?” and then Add New Employer.

  • Disclose this under the Business Relationships (also known as Financial Relationships) tab in BRR.
  • Answer ‘yes’ to the question “Do you or your Family Members have Financial Relationships or Consulting Relationships with any Business Entity(ies)?” and then Add a New External Entity. 

  • Disclose this under the Intellectual Property tab in BRR.
  • Answer ‘yes’ to the question “Do you or your Family Members have any Intellectual Property, including those owned by the University of Utah, that are reasonably related to your professional responsibilities to the University?” and then Add New Disclosure.

  • Disclose this under the Business Relationships (also known as Financial Relationships) tab in BRR.
  • Answer ‘yes’ to the question “Do you or your Family Members have Financial Relationships or Consulting Relationships with any Business Entity(ies)?” and then Add a New External Entity. 

  • Disclose this under the Business Relationships (also known as Financial Relationships) tab in BRR.
  • Answer ‘yes’ to the question “Do you or your Family Members have Financial Relationships or Consulting Relationships with any Business Entity(ies)?” and then Add a New External Entity. 

  • Disclose this under the Travel tab in BRR.
  • The current question solicits this information from all investigators who participate in PHS funded research (ex. NIH, NCI, etc). Answer ‘yes’ to the question “Do you have travel during the past 12 months that you are required to disclose?” and Add a New Disclosure.

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Last Updated: 7/26/21