NASA Restrictions on Funding Activities with China


On February 9, 2012, an information circular (GIC 12-01) was issued by NASA regarding recently enacted funding restrictions with respect to China. NASA reissued and clarified on September 26, 2012, (GIC 1201A) that this restriction is not citizenship based but rather affiliate based. Specifically, the restrictions state:

“NASA is restricted…from entering into or funding any  grant or cooperative agreement of any kind to  participate, collaborate, or coordinate bilaterally  in any way with China or any Chinese-owned company at the prime recipient level or at any subrecipient level,  whether funded or performed  under a no-exchange of funds arrangement.”

NASA has created a FAQ website for this funding restriction.

Who it affects?

This restriction applies to all NASA projects with funds appropriated on or after April 25, 2011, and all future appropriations, whether performed on-campus or off, within the U.S. or abroad, that involve any UCF faculty, staff, or students.  

What must be done?

UCF proposals for NASA, are now required to include the following assurance:

“The proposer represents that the proposer is not China or a Chinese-owned company, and that the proposer will not participate, collaborate, or coordinate bilaterally with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.”

UCF Awards and Subawards from NASA must include a similarly worded restriction regarding use of funds.

How is this done?

To assist the UCF research community, the Office of Research & Commercialization will request UCF Principal Investigators funded by NASA since April 25, 2011, or those seeking NASA funds,  to complete a basic questionnaire, and the ORC Office of Compliance will seek  guidance from NASA to confirm the necessary assurances.


For any questions, please contact your contract manager or the Office of Research & Commercialization, Export Compliance Officer 407-882-0660.