Foreign Talent Recruitment Programs

Participation in a Foreign Talent Recruitment Program (FTRP) can create conflicts of interest, conflicts of commitment and research security concerns. 

Identifying FTRPs

The US Government expressly prohibits engagement in certain FTRPs, designated as “malign foreign talent recruitment programs” (MFTRPs), when applying for, or receiving, US federal funding. 

Researchers must secure written approval from their Dean, department head or assigned supervisor before engaging in any activity that may give rise to a conflict of commitment (e.g., FTRP participation).

Many governments use Foreign Talent Recruitment Programs (FTRPs) to attract and recruit researchers working internationally in priority fields to support their economic, political, and strategic goals. FTRPs may be administered by research institutions and centres located in the foreign state, or by local, provincial, or national governments. In many cases, a researcher is contacted directly with an invitation to join the FTRP.

Not all FTRPs pose a risk to the safeguarding of research, however researchers should consider how participating in an FTRP may intersect with institutional policies and potentially affect their eligibility for certain funding.

All UBC researchers must disclose their participation in FTRPs under UBC’s Conflict of Interest (COI) policy. Disclosing a COI helps research supervisors to assess and manage potential conflicts and does not necessarily indicate wrongdoing.

Research security risks

Certain FTRPs are organized, managed, or funded by governments or arms-length government instruments or entities, with the covert purpose of acquiring research or technology. FTRPs can be used to manipulate and misuse research in unintended or unauthorized manners, such as for military purposes or the violation of human rights. Some FTRPs may even request certain activities that put researchers and their work at risk, and make them in violation of institutional and funding agency policies.

Researchers and their work may be at risk if the FTRP requires them to: 
  • Transfer research data, knowledge, technology, expertise, intellectual property and other non-public information without consent or authorization;
  • Commercialize Intellectual Property in the foreign country where the FTRP is administered without disclosing this activity to UBC;
  • Recruit other researchers to enrol in the FTRP;
  • Set up a laboratory or company in the foreign country where the FTRP is administered;
  • Refrain from disclosing their participation in, or any other activities associated with, the FTRP to UBC.
     
Typical FTRPs provide researchers with incentives, such as:  
  • Research funding, financial compensation or other forms of remuneration;
  • In-kind support and resources, such as the access and use of labs, data, and/or equipment;
  • Complimentary travel expenses;
  • Honorific titles and awards; and
  • Employment opportunities, including appointments at foreign institutions.
     

Researchers should implement best practices to safeguard their research when considering whether to participate in these FTRPs.

FTRPs affect eligibility to US federal funding

If you intend to apply to US federal funding, participating in certain FTRPs can restrict your eligibility to that funding. Any researcher considered a “covered individual” by the US CHIPS and Science Act of 2022 cannot participate in any “malign” FTRPs (MFTRP).

Covered individuals applying for National Science Foundation (NSF) grants became subject to these requirements in May 2024. The requirements come into effect for all other US federal grants as of August 9, 2024, including grants administered by the US National Institutes of Health (NIH), Department of Defense (DoD), and the Department of Energy (DoE).

Determining if US federal funding requirements apply to you:
  1. Determine if you are a “covered individual”: Covered individuals includes Principal Investigators (PIs), senior/key personnel, and "any individual who contributes in a substantive, meaningful way to the scientific development or execution of a research and development project." Agencies may also define other individuals as covered persons as appropriate and consistent with their mission; and,
  2. Determine if any FTRPs you participate in are considered “malign”: Participation in these programs is prohibited and must be ended prior to certifying and applying. Participation in all FTRPs must be declared at the time of application.

When you apply for US federal funding, you must certify that you are not involved in an MFTRP, and re-certify this status every year for the grant’s duration. Covered individuals must also declare any FTRP they are involved in, regardless of whether they are malign or not.

Certain FTRPs can affect eligibility to Canadian federal funding

If an FTRP is administered by a Named Research Organization, participating in one could constitute establishing an affiliation and would make the researcher(s) ineligible for Government of Canada funding that is subject to the Policy on Sensitive Technology Research and Affiliations of Concern. 

FTRPs can conflict with UBC policies

An FTRP may request its participants to undertake activities that could place them in conflict with several institutional policies, including UBC’s policies on: 

All UBC researchers must disclose their participation in FTRPs as and when the participation occurs to remain compliant with UBC’s COI policy. Disclosing a COI does not necessarily indicate wrongdoing and can help researchers assess and manage any potential conflict.

US Office of Science and Technology Policy: Memo to the Heads of Federal Agencies re: Foreign Talent Recruitment Programs

Useful UBC Resources: Identifying Conflicts of Interest, Identifying Conflicts of Commitment

 

 

 

 

Part of the VP Research & Innovation portfolio

UBC Research Security Office

Suite 580, Walter C. Koerner Library, 1958 Main Mall
Vancouver, BC Canada
E-mail research.security@ubc.ca

UBC receives support for managing its research enterprise from the federal Research Support Fund.

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