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Research Report

3 ways CROs can proactively guard against the threat of foreign interference in research

November 6, 2019

While geopolitical tensions often play out far from the ivory tower of higher education, foreign policy changes (and the resulting tensions) under the Trump presidency have a very real impact for universities—especially the office of research. The continued trade war with China has played out on campuses since the summer of 2018, when the National Institutes of Health sent letters to over 10,000 research organizations warning of threats from China. In response, MD Anderson Cancer Center and Emory University fired researchers who failed to disclose foreign ties. Events have only escalated since then. In August of 2019, a professor at the University of Kansas was indicted on federal fraud charges.


The number of research organizations warned about threats from China by the National Institutes of Health
The number of research organizations warned about threats from China by the National Institutes of Health

These actions have an immediate impact on the research enterprise. Chief research officers (CROs) report changing attitudes on campus and express concern about the ability for faculty and staff to conduct the best research possible. More alarmingly, CROs acknowledge the political landscape could deteriorate more and require further action on their part. However, research leaders do not know what to expect—or how to respond. 

To help leaders prepare, the University Research Forum has convened groups of CROs across the past two months to discuss foreign interference in research. This article captures three important takeaways from the executive-level conversations—and what universities should do immediately to get ahead of potential problems.

1. Universities’ COI policies are overdue for an update

All research universities gather conflict of interest (COI) information from faculty through channels such as annual activity and COI reporting forms. Most institutions also have mechanisms to review reported conflicts of interest and create mitigation plans for activities that raise red flags. However, some CROs reported that their institutional forms and polices were not comprehensive or clearly worded enough, especially when asking about foreign talent recruitment programs.

To prepare, universities must:

  • Update conflict of interest forms to capture all foreign relations information
  • Establish international research review committees to vet opportunities against risks

To see an updated policy, check out the University of North Carolina at Chapel Hill’s guidance

2. Institutions are being pressured to do more but lack clear federal guidelines

As with most federal regulations, institutions face heightened scrutiny with no administrative support when it comes to protecting against foreign interference in research. However, the situation is even more fraught for leaders, as the federal government has not issued formal guidelines for institutions to comply with. Some campuses even report conflicting messages from different agencies. As a result, research offices have surfaced more issues than they have capacity to respond to. Between reviewing COI forms to ensuring sensitive federal research can proceed appropriately to updating facility access policies, research offices face significant gaps in both capacity and expertise.

Given this vacuum, the most critical action CROs can take now is to involve other senior leaders. This includes the board, president, provost, and general counsel, all of whom should be consulted as the institution assesses potential liabilities and determines the most appropriate course of action. Additionally, research offices can mitigate future risk by taking the following steps:

  • Strengthen on-campus visitor procedures
  • Tighten visiting scholar policies
  • Insert additional disclosure questions into grant submission forms

3. Without guidance, universities have two choices: cooperate or challenge

Despite the absence of clear federal guidelines on how to guard against foreign interference in research, institutions are being forced to act. For instance, some universities have reported visits from FBI agents. For the most part, these visits are focused on discovery and informing universities of potential threats—meaning agents do not have subpoenas or open criminal inquiries. But institutions are taking one of two responses when engaging with the federal government on foreign interference investigations: cooperative or adversarial.


Institution chooses to voluntarily and proactively engage with federal agencies to share information, data, and access to university facilities and systems

  • Meets regularly with federal agents to pass high-level and case-specific intelligence
  • Grants permission for agency to review university documents and systems without any legal requirement to do so
  • Makes university staff readily available to support investigations
  • Permits routine monitoring of university facilities and faculty


Institution withholds collaboration with federal agencies and only reacts after sufficient due process has been demonstrated through a legal or administrative means (e.g., subpoena)

  • Abstains from communication with federal agents until required to do so
  • Refuses to grant agency access to university documents and systems without legal mechanism
  • Denies university staff support until formal investigation commences
  • Pushes back on attempts by agencies to monitor university facilities and faculty

Some CROs have responded cooperatively, giving agents access to spaces and documents of interest. Others have been less forthcoming in the name of academic freedom and faculty rights, deferring any collaboration with the government, most frequently the Department of Justice and the FBI, until they take more formal actions, such as receiving a subpoena or search warrant.

Research leaders have not yet coalesced around a single response, but all agree that general counsel must be involved in these conversations. To prepare, universities must coordinate with senior leadership and their general counsel to determine how they will respond if they receive a request from the government.

Recommended proactive steps to take


Update Conflict of Interest forms to capture all foreign relations information

Establish international research review committees to vet opportunities against risks

Strengthen on-campus visitor procedures; tighten visiting scholar policies

Insert additional disclosure questions into grant submission forms

Join and contribute to cross-university international risk assessment databases

Identify and catalog technology and equipment from foreign countries

Check grant submissions against disclosure forms to head off inaccuracies

Update internal review processes as global relationships, polices change

Consider domestic-made alternatives when updating/replacing technology