Based on the U.S. Office of Science and Technology Policy's National Security Presidential Memorandum 33 (NSPM-33), a foreign/international talent recruitment program (FGTRP) is an effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship, national origin, or full-/part-time status).
FGTRPs raise U.S. sponsor concerns when they appear to operate with the intent of acquiring proprietary technology or software, unpublished data and methods, or other intellectual assets to further the military and/or economic goals of a foreign government through actions including, but not limited to:
- Incentivizing/compensating the FGTRP participant to relocate physically to a foreign country in order to import/acquire the proprietary technology, software, etc.;
- Allowing for or encouraging the FGTRP participant to receive U.S. Federal research funds while concurrently working at and/or receiving compensation from a foreign institution for the same, or similar, work;
- Directing FGTRP participants not to disclose their participation to United States entities;
- Compelling FGTRP participants to enter into contracts that conflict with their responsibilities to, or that are disallowed by Michigan Tech.
Compensation may include cash, research funding provided directly to the individual and not through Michigan Tech, access to research facilities or other in-kind support, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration/consideration.
Michigan Tech researchers are advised that participation in an FGTRP must be disclosed to the university by contacting researchsecurity-l@mtu.edu, and to federal sponsors in Biosketches and Current & Pending/Other Support, as applicable.
Federal governments consider this disclosure in determining funding. Failure to disclose participation in an FGTRP has resulted in legal action by the U.S. government against researchers who are engaged in federally-sponsored research.
If you have question regarding conflict of interest procedures or funding agency disclosure requirements, please contact the Conflict of Interest Office at coic@mtu.edu.
Malign Foreign Talent Recruitment Programs
Avoiding Substantial Conflicts
Michigan Technological University researchers cannot accept or benefit from research resources that are in conflict with their obligations to Michigan Tech, or with the commitments they make to their U.S. federal funding agencies. Malign foreign government talent recruitment programs generally involve obligations that conflict with Michigan Tech policies and U.S. federal funding, and so qualify as substantial conflicts of interest.
Prohibition on Malign Foreign Government Talent Recruitment Program Participation
Because malign foreign government talent recruitment programs qualify as a substantial conflict of interest, Michigan Tech researchers who are participating in a malign foreign talent recruitment program are prohibited from participating in federally funded research at Michigan Tech.
Researchers serving as senior / key personnel must certify at proposal, and annually for the duration of the award, that they are not party to a "malign" foreign talent recruitment program.
In addition, principal investigators / key personnel:
- are prohibited from participating in a federally funded research and development project if they are currently participating in a malign foreign talent recruitment program
- must disclose if they are a party to any foreign talent recruitment program
Researchers serving as senior / key personnel must certify at proposal, and annually for the duration of the award, that they are not party to a "malign" foreign talent recruitment program. Please review "Is My Talent Program Considered Malign?"
For more information, please review the "Memorandum from the Office of Science and Technology Policy"