Office of Research



Office of Research

International Collaboration

The University of Central Florida (UCF) is committed to facilitating open and publicly accessible research and scholarly activities both domestically and internationally. International activities and partnerships are a valued and key part of the academic experience. UCF is also committed to adhering to federal and state laws and regulations related to mitigating the risks associated with inappropriate foreign influence. The purpose of this webpage is to assist the UCF community in better understanding these requirements and ways to mitigate the risks associated with inappropriate foreign influence. OICEC encourages the UCF community to continue engaging in international partnerships and activities and is here to assist.

Inappropriate Foreign Influence

The U.S. Government, including several federal agencies that fund UCF’s research, has expressed concerns regarding inappropriate influence by foreign entities, foreign governments, and foreign individuals on U.S. institutions and researchers. This is commonly referred to as foreign influence. The Florida State Legislature has also expressed these concerns.

Key concerns related to inappropriate foreign influence include, but are not limited to:
  • The failure of researchers to disclose support from outside activities or foreign organizations.
  • Unlawfully sharing non-public information by researchers.
  • Unlawful transfer of U.S. intellectual property, data, or unpublished research results.
  • Unlawful transfer of research materials and samples.
  • Agreements with foreign entities that may impose obligations on researchers that are contrary to university policies and/or federal and state laws and regulations.
  • Data security and cyberattack vulnerabilities. 

The above concerns impact all types of scholarly activity, including, but not limited to, research, student engagement, and intellectual property protection.  Inappropriate foreign influence can have a major impact on the integrity of UCF and UCF’s ability to obtain federal funding. 

What is an example of inappropriate foreign influence?

An example of inappropriate foreign influence includes participation in a foreign government talent/recruitment program and failing to disclose participation in that program in accordance with applicable federal and state laws and regulations. Such programs are generally defined as foreign state-sponsored attempts to acquire U.S. scientific-funded research or technology through foreign government-run or funded recruitment programs.  Unfortunately, a number of foreign government talent/recruitment programs are intertwined with the concerns outlined above.

Pursuant to the CHIPS and Science Act of 2022, UCF prohibits (1) UCF employees and (2) individuals applying for or receiving federal funding through UCF, from participating in a Malign Foreign Talent Recruitment Program (MFTRP).

For more information on MFTRPs please see: https://www.congress.gov/117/plaws/publ167/PLAW-117publ167.pdf.

For questions regarding MFTRPs, please contact OICEC@ucf.edu.

What Do Researchers Need to Do?

The best way for researchers to mitigate concerns regarding inappropriate foreign influence is by educating themselves, their staff, and their students about relevant regulations and policies, completing all federal, state, and UCF disclosure requirements, and providing ongoing communications regarding any new or changing relationships with foreign entities.

UCF has policies and procedures in place to assist with meeting the above requirements, but in general, researchers should:

  • Meet sponsor disclosure requirements.

  • Disclose financial interests and outside activities to UCF.

  • Ensure that they and their staff are current with Export Control policies and procedures.

  • Disclose Inventions and Other Intellectual Property.

  • Limit engagements with High-Risk Entities.

Meet Sponsor Disclosure Requirements

Disclosure Requirements Overview

When seeking federally funded research, many federal agencies have added or reiterated reporting requirements related to outside activities and financial interests with foreign entities. Please note that federal and state agencies may release further guidance over the coming months, so be aware that information and requirements may change at any time. Multiple federal agencies, including, but not limited to, DOE, DOD, NSF, and NIH, have reporting requirements related to foreign activities when seeking federally funded research.

Agency-Specific Disclosure Requirements

  • DOE, DOD, and NSF: Foreign activities should be disclosed within Current and Pending Support and/or the Biosketch.

  • NIH: Foreign activities should be disclosed in Other Support, Foreign Component, Facilities and Resources, and/or the Biosketch.

What is required to be disclosed depends on the particular agency. To identify disclosure requirements related to a particular funding opportunity, individuals seeking federal funding for research should review the individual agency announcement, the funding notice, the agency guidebook, and the award terms and conditions.

Please note, the failure to fully disclose foreign activities to federal agencies can have serious consequences on the ability of individuals and UCF to obtain future federal funding. If you have questions regarding particular disclosure requirements, please work with your proposal manager and/or contract manager.

Disclose Financial Interests and Outside Activities to UCF

In addition to the federal requirements mentioned above, Florida State Statute 1012.977 was enacted on July 1, 2020, to also address the concerns related to inappropriate foreign influence. To assist faculty, staff, and students in meeting these reporting requirements, UCF amended the online AA-21 disclosure to include a new question, Question 12. Question 12 only applies to individuals engaged in research at UCF. The purpose of obtaining responses to this question is to provide employees the mechanism to comply with the federal and state disclosure requirements and allow UCF to evaluate whether there is a potential inappropriate foreign influence risk that requires additional review by UCF.

For more information about what and how to disclose to UCF, please visit compliance.ucf.edu/conflict-of-interest/.

For questions regarding the AA-21 Form and process, please contact: PCA@ucf.edu.

Ensure that You are Current with Export Control Policies and Procedures

In general, export controls are federal laws that govern the export of controlled items and technical data to foreign countries and foreign nationals. While inappropriate foreign influence does not just target export-controlled technologies and data, the UCF community can help mitigate the risks of inappropriate foreign influence by making sure to comply with all applicable U.S. export control regulations, UCF export policies, and project-specific plans (if applicable).

For more information on export control compliance, please see www.research.ucf.edu/ExportControl/index.html.

For questions regarding export control compliance, please contact: Ashley.Guritza@ucf.edu.

Disclose Inventions and Other Intellectual Property

Another way to help mitigate the risks of inappropriate foreign influence is to disclose intellectual property to the UCF Technology Transfer Office in accordance with UCF policy.

For more information on intellectual property protection and UCF policies, please see tt.research.ucf.edu.

Limit Engagements with High Risk Entities

The U.S. Government prohibits U.S. entities from engaging in activities with parties that are identified on the U.S. Denied Parties Lists. Separate from these lists, certain entities have been identified through publicly available information as entities known to target U.S. technology and/or have affiliations that are counter to U.S. National Security interests (High-Risk Entities). At this time, UCF faculty, staff, and students should consider the risks associated with engaging in activities with High-Risk Entities.

For more information on High-Risk Entities, click here: https://www.research.ucf.edu/ExportControl/GuidanceEngagingInActivitiesWithHighRiskEntities.html.

International Collaborations

International activities and partnerships are a valued and key part of the academic experience. With that said, in certain situations there are federal regulations, state regulations, and UCF policies that may impact international activities, including, but not limited to, collaborating with international entities, hosting foreign nationals, and international travel.

Export Control

When engaging in international collaborations, the UCF community should always keep in mind the U.S. export control regulations and what is required to comply with those regulations. For more information on the U.S. export control regulations, click here.

Sanctioned Countries and Restricted Parties

The Office of Foreign Assets Control (OFAC) enforces all U.S. embargo and sanction programs. Depending on the sanction/embargo program, different activities may or may not be prohibited without a specific government authorization or license.

In general, under comprehensive sanctions programs, all activities are prohibited, including, but not limited to, exporting to, importing from, financial transactions of any kind, and/or providing services of any kind. Currently, the “comprehensively” sanctioned countries include Cuba, Iran, Syria, and North Korea.

In addition, multiple agencies of the U.S. Government have identified entities and individuals as sanctioned entities/persons. The U.S. Department of State has also identified entities that target U.S. technology and/or have affiliations that are counter to U.S. National Security interests (High Risk Entities). Unless a license is obtained from the U.S. Government, most activities with sanctioned entities/persons are prohibited. In addition, due to the risks associated with High Risk Entities, UCF generally does not engage in activities with High Risk Entities. UCF has several internal processes to assist the UCF community in identifying sanctioned entities/persons and High Risk Entities. General information related to these entities/persons can be obtained at:

Hosting Foreign Nationals

As part of the U.S. Citizenship and Immigration Services (USCIS) Form I-129 process, UCF is required to perform a “deemed export attestation.”  Specifically, UCF must certify whether an export control license is or is not required for the foreign national to perform their responsibilities at UCF. UCF Global will request that units wanting to sponsor a visa complete the UCF Non-Immigrant Export Control Questionnaire. OICEC will review this Questionnaire to assist UCF units in proactively identifying when a deemed export license may be required. Note: The visa process is separate from the foreign influence screening process required by Florida Statute 1010.35.  If screening is required, the screening process must be completed before OICEC can provide the “deemed export attestation.”

For more information on the UCF Visa process, please see: https://global.ucf.edu/

International Travel

Pursuant to Florida Statute 1010.36, preapproval from UCF is required for all faculty, researchers, and research department staff prior to engaging in employment-related international travel. For more information on the UCF travel process please see: https://global.ucf.edu/international-health-and-safety/travel-registration/.  As part of the UCF travel process, OICEC conducts a review of international travel to assist in determining whether an export control license may be required and to help identify inappropriate foreign influence risks.

If you intend to export (i.e., ship or take) any UCF owned material or technology during your travels, you are required to comply with all applicable U.S. Customs and export control regulations. If certain requirements are met, a lot of commonly used technology can qualify for the Tool of Trade Exception under the Export Administration Regulations.

Tip from OICEC: If you don’t need it, don’t take it with you!