Enhancing the Security and Integrity

of America’s Research Enterprise

The White House Office of Science and Technology Policy

www.whitehouse.gov/ostp

www.ostp.gov

@WHOSTP
Key takeaways

• The integrity of the research enterprise rests upon core principles and values.

• Principled international collaboration and foreign contributions are critical to the 

success of the U.S. research enterprise.

• Some individuals and foreign governments violate core principles of integrity and pose 

risks to research security.

• Hidden diversions of intellectual property weaken the U.S. innovation base and 

threaten our security and economic competitiveness.

• The U.S. Government is taking deliberate steps to address risks to research security 

and integrity while maintaining an open and collaborative enterprise.

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INTEGRITY OF THE RESEARCH 

ENTERPRISE RESTS UPON CORE 

PRINCIPLES AND VALUES

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Integrity of the research enterprise rests upon core 

principles and values

• Openness and transparency enable productive collaboration and help ensure appropriate disclosure 

of potential conflicts of interest and commitment.

• Accountability and honesty help acknowledge errors and correct behaviors that can hamper progress.

• Impartiality and objectivity protect against improper influence and distortion of scientific knowledge.

• Respect helps create an environment where all can be heard and contribute.

• Freedom of inquiry allows individual curiosity to guide scientific discovery.

• Reciprocity ensures scientists and institutions exchange materials, knowledge, data, access to facilities 

and natural sites, and training in a way that benefits collaborating partners proportionally.

• Merit-based competition helps ensure a level playing field where the best ideas and innovations can 

advance. 

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The principles and values that underpin the integrity of the research enterprise 

comport with American values.
Individuals, institutions, and governments share 

responsibility for integrity in the research enterprise

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Principles of integrity for responsible 

individuals and institutions:

Openness and Transparency

Accountability

Impartiality and Objectivity

Honesty

Respect 

Principles of integrity for responsible 

governments, reflected in U.S. government 

policy:

Openness and Transparency

Accountability

Freedom of inquiry 

Reciprocity

Merit-Based Competition

Behaviors that violate these shared principles jeopardize the

integrity of the research enterprise.
PRINCIPLED INTERNATIONAL 

COLLABORATION IS CRITICAL TO SUCCESS

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International science is frontier science

• Enables cutting-edge research that no 

nation can achieve alone

• Strengthens scientific and diplomatic 

relations 

• Leverages resources, including funding, 

expertise, and facilities

• Trains a robust S&T workforce capable of 

solving global problems

• International students and scholars 

contribute significantly to the U.S. research 

enterprise

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Elizabeth E. Lyons, E. William Colglazier, Caroline S. Wagner, Katy Börner, David M. Dooley, C. D. Mote 

Jr., and Mihail C. Roco, “How Collaborating in International Science Helps America ” Science & 

Diplomacy, Vol. 5, No. 2 (June 2016).

In April 2019, a global collaboration of scientists at 60 institutions 

operating in 20 countries and regions captured the first ever 

image of a black hole. 

Photo credit: NSF, The Event Horizon Telescope Collaboration. (https://eventhorizontelescope.org/)
RISKS TO RESEARCH SECURITY AND 

INTEGRITY 

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Some individuals and foreign governments violate core 

principles of integrity and pose risks to the research enterprise

Risks to the Integrity of the Research Enterprise

• Violations of responsible and ethical conduct of research

• Actions that undermine peer review and grant award processes

Risk to National Security

• Hidden diversions of research and/or resources that threaten U.S. leadership in 

emerging science and technology 

Risk to Economic Security

• Hidden diversions of research and/or resources that weaken the innovation base and 

threaten economic competitiveness

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Transparency and full disclosure are needed to properly 

assess risks.

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For the purposes of this presentation:

A conflict of interest is a situation in which an individual, or the individual’s spouse or dependent 

children, has a financial interest or financial relationship that could directly and significantly affect the 

design, conduct, reporting, or funding of research.

A conflict of commitment is a situation in which an individual accepts or incurs conflicting obligations 

between or among multiple employers or other entities. Many institutional policies define conflicts of 

commitment as conflicting commitments of time and effort, including obligations to dedicate time in 

excess of institutional or funding agency policies or commitments. Other types of conflicting obligations, 

including obligations to improperly share information with, or withhold information from, an employer 

or funding agency, can also threaten research security and integrity, and are an element of a broader 

concept of conflicts of commitment. 
Examples of behaviors that increase risk and can harm 

the research enterprise

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Irresponsible Conduct that Violates Funding Agency 

and Institutional Policies: 

• Failures to disclose:

• Financial conflicts of interest

• Conflicts of commitment 

• External employment arrangements 

• Financial support that overlaps with U.S. funding 

• Shadow laboratories or other parallel research 

activities

• Diversion of intellectual property 

• Peer review violations

Examples of Behaviors that May Violate Laws: 

• Theft or diversion of materials and intellectual capital

• Grant Fraud 

Potential Impacts:

• Distorted decisions about appropriate use of 

taxpayer funds 

• Hidden transfers of information, know-how, 

data, and time

• Diversion of proprietary information and 

pre-publication data to foreign entities

• Loss of Federal research funding, or need to 

replace key personnel

• Damage to the reputation of research 

institutions and researchers

• Reputational, career, and financial 

detriment to individuals

• Loss of taxpayer and public trust in the 

research enterprise 
Impacts:

• Distorts decisions 

about appropriate use 

of taxpayer funds 

• Hidden transfers of 

information, knowhow, data, persontime

Case study 1: Undisclosed conflicts of interest and commitment 

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• Undisclosed founder and primary shareholder of a 

publicly traded Chinese biotech company that 

specialized in the same work he performed at UCSD

• Multiple undisclosed subsidiaries and additional 

companies in the U.S., China, and the Cayman 

Islands

• Undisclosed member of a foreign government 

sponsored talent recruitment program. 

Source: https://inewsource.org/2019/07/06/thousand-talents-program-china-fbi-kang-zhang-ucsd/

Unreported Conflict 

of Interest

Unreported Conflict 

of Interest

Unreported Conflict 

of Commitment 

Former chief of eye genetics at the Shiley Eye Institute at University of 

California San Diego Health:

• Received $10 million in NIH grants during 11 years at UCSD 

• Founded U.S. pharmaceutical R&D company Calcyte Therapeutics

Researcher resigned from U.S. institution. 
Impacts:

• Distorts decisions 

about appropriate use of 

taxpayer funds 

• Hidden transfers of 

information, know-how, 

data, person-time

Case study 2: Leadership failures to disclose conflicts

of interest and commitment

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• Did not report personal payments or foreign bank 

accounts totaling hundreds of thousands of dollars in 

research subsidies and annual salaries. 

• Undisclosed members of a foreign government 

sponsored talent recruitment program. 

Sources: https://www.sciencemag.org/news/2020/01/moffitt-cancer-center-details-links-fired-scientists-chinese-talent-programs

https://www.tampabay.com/news/health/2020/02/07/moffitt-returns-1-million-to-state-money-was-linked-to-scientist-with-china-ties/?clavis&utm_expid=.rZxRlJI0T86fmAabR1Jv8w.1

Unreported Conflict 

of Interest

Unreported Conflict 

of Commitment 

Six scientists at the Moffitt Cancer Center, including the President and CEO 

and the Center Director, resigned due to violations of conflict of interest 

rules through their work with China.

Researchers resigned from U.S. institution. 

The Center returned more than $1 million in state money.
Unreported Conflict 

of Commitment

Violation of Peer 

Review Process

Impacts:

• Loss of taxpayer and 

public trust in the 

research enterprise 

• Distorts decisions about 

appropriate use of 

taxpayer funds 

• Diversion of proprietary 

information and prepublication data to foreign 

entities

Case study 3: Distortion of the peer review process

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Researcher served as a designated peer reviewer for 

funding agency grants.

• Undisclosed participant in a foreign-government 

sponsored Talent Recruitment Program

• Diverted proprietary information: Emailed grant 

applications to scientists in China and to some 

U.S.-based persons

• Researcher instructed one recipient of the 

information to “keep it to yourself”

• Stated in another note, “Here is the bone and 

meet [sic] you need.”

• Emailed a grant application to a Chinese 

academic institution offering: “Some methods 

you may learn from this proposal. Keep this 

confidential.”

Researcher elected to resign from MD Anderson.

Case as reported by the Cancer Letter, April 26, 2019
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Nine hackers working for the Mabna Institute, an Iranian 

government-sponsored entity, were indicted in 2018 for 

allegedly hacking into at least 144 U.S. universities and 176 

universities in 21 foreign countries.

• Hackers allegedly stole 31.5 terabytes – about 15 billion 

pages – of academic data. Collectively, the victim 

universities spent an estimated $3.4 billion to acquire 

the data.

• Hackers waged a phishing campaign that successfully 

compromised the accounts of some 8,000 accounts to 

steal research and other academic data, such as 

journals, theses, dissertations and electronic books. 

Theft or 

diversion of 

materials and 

intellectual 

capital

Impacts:

• Diversion of 

proprietary 

information and prepublication data to 

foreign entities

Case study 4: Cyber theft of data 

Charged by DOJ on March 23, 2018 for conspiracy to commit computer intrusions, conspiracy 

to commit wire fraud, unauthorized access to a computer, wire fraud, and aggravated 

identity theft. Defendant(s) are presumed innocent until proven guilty.
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Researcher found guilty of conspiring to commit federal 

grant fraud, making false statements, and obstruction by 

falsification 

• Founded a U.S. company and applied for DOE and NSF 

grants to fund his U.S. company to conduct research 

between 2014-2016; at least some research had already 

been completed in China, including by researcher’s own 

“Satellite Lab”

• Signed undisclosed five-year employment agreement 

with Chinese University in 2014 to serve as Director of 

Research Institute

Grant Fraud 

“Shadow Lab” Impacts:

• Distorts decisions 

about appropriate use 

of taxpayer funds 

Researcher was found guilty on February 21, 2019. 

Case # 7:17-cr-00073 (Western District of Virginia)

Unreported 

Conflict of 

Commitment

Case study 5: Criminal grant fraud 
RISKS ASSOCIATED WITH FOREIGN 

GOVERNMENT SPONSORED TALENT 

RECRUITMENT PROGRAMS

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Some government-sponsored talent recruitment 

programs are problematic

A foreign government sponsored talent recruitment program is an effort directly or indirectly organized, 

managed, or funded by a foreign government to recruit science and technology professionals or students 

(regardless of citizenship or national origin). 

• Many countries sponsor talent recruitment programs for legitimate purposes of attracting researchers in targeted fields

• Many programs utilize legitimate means of attracting talent, including offering research fellowships and grants to 

incentivize researchers to physically relocate

• However, some programs encourage or direct unethical and criminal behaviors 

• Contracts for participation in some programs, including some sponsored by the Chinese government, include language 

that creates conflicts of commitment and/or conflicts of interest for researchers

• Requirements to attribute awards, patents, and projects to the foreign institution, even if conducted under U.S. 

funding 

• Requirements to recruit or train other talent recruitment plan members, circumventing merit-based processes 

• Requirements to replicate or transfer U.S.-funded work in another country

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Transparency and full disclosure are essential to properly assess risks.
Example talent recruitment contract: 

Undisclosed employment

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• U.S.-funded 

researcher 

working full 

time at a U.S. 

institution

• Undisclosed 

employment 

in another 

country for 9 

months out of 

the year

(Foreign 

institution)

(U.S. –funded researcher)

U.S.-funded

researcher

Foreign 

institution U.S.-

funded

researcher

(Foreign 

institution)

Foreign 

institution

Foreign 

institution

(U.S. –funded researcher)

Foreign 

institution

Foreign 

institution

U.S. 

researcher
Example talent recruitment contract: 

Directed output 

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• U.S.-funded researcher is party 

to an undisclosed contract 

with a foreign institution

• U.S. researcher is obligated to 

file 2-3 foreign patents within 3 

years. 

• The nondisclosure of this 

contract does not give the 

university or the Federal 

funding agency knowledge of 

its patent rights. 

• In some cases U.S.- funded 

researchers have secured 

foreign patents based at least 

in part on their U.S.-funded 

work.

(Foreign 

institution)

(U.S.-funded

researcher)

(U.S.-funded

researcher)
• U.S. Government employee 

signed an undisclosed talent 

program contract with a 

Foreign institution.

• Contract raises concerns of 

preferential treatment to 

certain potential students

• Undisclosed commitment of 

the U.S. institution to a 

foreign institution 

• Researcher received 

undisclosed support from 

foreign research team

(U.S.-funded

researcher)

(Foreign 

institution)

(Foreign 

institution)

(Foreign 

institution)

(U.S.-funded

researcher)

Example talent recruitment contract: 

Other support 

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These conditions are problematic for 

the U.S. Government and the 

Research Institution. 

This contract cedes credit from the 

work conducted by a federally 

funded researcher and employee of 

a U.S. institution to a foreign 

institution. 

These conditions may be 

problematic for the researcher- both 

the foreign institution and foreign 

government need to approve the 

application for termination of the 

contract. Penalty for breach of 

contract is not clearly defined. 

(Foreign 

institution)

(U.S.-funded

researcher)

(Foreign 

institution)

(U.S.-funded

researcher)

(U.S.-funded

researcher)

(U.S.-funded

researcher)

(Foreign 

institution)

(Foreign 

institution)

(U.S.-funded

researcher)

(U.S.-funded

researcher)

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Example talent recruitment contract: 

Attribution and liabilities
Example talent recruitment contract: 

Intellectual property

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Problematic for the Researcher, Research Institution, and U.S. Government: 

• U.S.-funded researcher is party to an undisclosed contract with a foreign government

• Foreign government dictates that any IP the U.S.-funded researcher develops should not be reported to 

the U.S. institution

• Foreign government dictates the portion of IP owned by the foreign institution 

U.S.

U.S. U.S.
Example talent recruitment contract: Intellectual 

property

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Contract language from Case # 7:17-cr-00073 (Western District of Virginia)

Problematic for the Research Institution, and U.S. Government: 

• U.S.-funded researcher is party to an undisclosed contract with a foreign government

• Researcher is contracted to transfer 2-3 science and technology achievements to the foreign 

institution in 3-4 years. 
Example talent recruitment contract: Objectives 

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• U.S.-funded researcher is party to an undisclosed contract with a foreign 

government

• Foreign institution dictates that the U.S.-based laboratory be moved to China; U.S. 

institution unaware of this commitment

U.S.-funded 

Researcher

(Foreign 

institution)

U.S.-funded 

Researcher

(Foreign 

institution)
Example talent recruitment contract: 

Problematic for researcher and institution

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Imposed secrecy 

Stringent 

restrictions on 

termination of 

Contract – the U.S. 

researcher cannot 

unilaterally 

terminate the 

contract.

U.S.-funded 

Researcher

U.S. –funded 

Researcher

Foreign 

institution
How widespread are behaviors that threaten research 

security and integrity?

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Inquiries from the National Institutes of Health are 

currently the most public. As of June 2020:

● Sent notices to over 87 academic and research 

institutions

● Identified concerns regarding more than 189 

scientists

● Nearly all in pre-clinical research, across many fields 

of biomedicine, all across the United States

The National Science Foundation’s inspector general 

has reported a 20% increase in caseload in the last year

• Data are incomplete but suggest widespread and 

systemic activity across geographic location and research 

discipline

• Incidents of concern are not unique to any one 

background, ethnicity, or nationality

• Other countries have identified similar behaviors in their 

research enterprises, and we are engaging with them to 

reach common awareness and share best practices

Many cases of concern have involved individuals with undisclosed participation in foreign 

government sponsored talent recruitment programs
Comprehensive risk assessment and risk mitigation require a range of measures and 

response mechanisms.

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Timeline of Case # 7:17-cr-00073 (Western District of Virginia)

2018

In many instances, institutions have taken 

administrative action to address 

inappropriate behaviors.

Prosecutions are consequential, but are not 

a substitute for an effective internal 

compliance program.

Criminal prosecutions provide an important but 

incomplete measure of research security risk
Some government sponsored talent programs are adapting in 

response to growing awareness of the risks they pose

Translated from a 2018 local talents program contract, 

sponsored by the Chinese National Natural Science Fund 

Commission:

III: Items to Pay Attention To

In order to further do a better job in ensuring the 

safety/security of overseas talents, [we] ask the 

organizations not use e-mails in sending out notifications 

for interview/defense. Instead, they should use telephone 

calls or faxes in giving notifications in the name of inviting 

[the candidates] to come back to China to attend academic 

conferences and forums, the words “1000 Persons Plan” 

shall not appear in the written notifications.

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U.S. GOVERNMENT ACTION

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Balancing Openness with Security
U.S. government coordination to address key areas that 

impact the American research enterprise

On May 6, 2019 The White House Office of Science and Technology Policy established the

Joint Committee on the Research Environment (JCORE) through the National Science 

Technology Council to address four critical issues related to the research enterprise. 

Four subcommittees focus efforts on:

1. Research Security: Balancing openness with strengthening the security of our research enterprise

2. Reducing Research Administrative Workload: Reducing the administrative burdens that impede 

critical scientific research while ensuring we have appropriate accountability and oversight

3. Rigor and Integrity in Research: Fostering a research enterprise that upholds freedom of inquiry, 

reciprocity, and promotes positive incentives that underscore sound research practices

4. Safe and Inclusive Research Environments: Ensuring that the research environment is an 

environment that is merit-based, safe, inclusive, equitable, and welcoming to all
Strengthening the security of the U.S. research enterprise

The JCORE Research Security Subcommittee aims to protect America’s research enterprise without compromising 

our values or our ability to maintain the innovation ecosystem that has underpinned our leadership in science and 

technology.

The Subcommittee is comprised of over 20 science and security Federal agencies, and co-chaired by White House 

Office of Science and Technology Policy, the National Institutes of Health, National Science Foundation, and the 

Department of Energy.

Research Security Subcommittee Focus Areas:

1. Appropriate and effective risk management 

2. Consistent, coordinated, and effective outreach to and engagement with academic and research institutions 

3. Coordinated guidance for Federal agencies 

4. Recommendations for academic and research institutions

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JCORE research security subcommittee actions 

• Developing guidance for Federal departments and agencies 

• Developing best practices for universities and other research institutions

• Letter to the United States Research Community

• Developing education and outreach materials that highlight examples of 

risks to research

• Engagement with Congress

• Coordinating with the National Academies of Sciences, Engineering, and 

Medicine on the Science and Security Roundtable as directed by the 

2019 National Defense Authorization Act

• Individual agencies are also taking policy actions in line with their 

mission

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Letter to the United States Research Community
Engagement and outreach

White House Summit on November 5th, 2019

• Convened more than 150 people from industry, academia, 

and the Federal government

• Provided and collected insights on the work of Joint 

Committee on the Research Environment (JCORE)

Request for Information on the American Research 

Environment on November 26, 2019, inviting the research 

community to provide input on all four JCORE focus areas 

Extensive interagency outreach to hundreds of institutions, 

faculty, and students across the country. 

Deep engagement with associations and societies, and with 

international partners. 

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White House National JCORE Summit 5 Nov 2019

Photo Credit: Erik Jacobs
Additional Administration Action Highlights 

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• Presidential proclamation to block certain graduate level and above Chinese nationals associated with entities in 

China that implement or support China’s Military-Civil Fusion strategy from using F and J visas to enter the 

United States. 

• The National Institutes of Health issued a Statement, sent letters to grantee institutions requesting information 

about undisclosed foreign ties, and since 2018 has identified concerns regarding more than 189 scientists. 

• The National Science Foundation issued a Dear Colleague letter, made policy changes to mitigate risks through 

changes to proposal submission requirements, and is acting on the recommendations of a study by the 

independent JASON group on research security. The JASON study identifies the threat of foreign influence as a 

complex issue that ‘can be addressed within the framework of research integrity’. 

• The Department of Energy issued a directive prohibiting participation by DOE laboratory personnel in talent 

recruitment programs sponsored by certain foreign governments of risk and established an S&T risk matrix to 

help protect identified emerging research and technology areas. 
Additional Administration Action Highlights 

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• The Department of State is engaging with partners to raise awareness of the risks of foreign interference on 

research integrity and security. 

• As part of its China Initiative , the Department of Justice developed an enforcement strategy that combines 

outreach and enforcement to address threats posed by non-traditional collectors, including in academia. Recent 

criminal prosecutions alleging fraud and false statements by academics have highlighted concerning patterns of 

behavior, many of which involve Chinese talent plans. 

• The Federal Bureau of Investigation’s Office of the Private Sector partnered with academic associations, hosted 

national level Academia Summits, and strengthened engagement with private industry and academia throughout 

the FBI’s 56 field offices. 

• The Office of the Director of National Intelligence and the National Counterintelligence and Security Center 

strengthened partnerships with academia to raise awareness and provide context to better understand and 

recognize foreign influence activities.
Additional Administration Action Highlights 

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• The Department of Agriculture issued guidance on the inclusion of U.S. bilateral Science and Technology 

Agreements in USDA S&T agreements with foreign governments to ensure consistent application of provisions, 

such as intellectual property rights and benefit sharing. USDA is conducting enhanced training and awareness 

for its workforce on promoting and protecting American research and development.

• The Department of Defense established a Research Protection Initiative to establish consistent standards for the 

reporting of conflicts, detect incidents of problematic behavior, and work with academic institutions to limit 

undue foreign influence in research awards.

• The Department of Education has established new information collection requirements and systems to improve 

the transparency of foreign funding of institutions of higher education, opened ten civil compliance 

investigations of U.S. universities for failing to disclose their financial relationship with foreign sources, and 

identified previously undisclosed foreign funding totaling approximately $6.5 billion and over $1 billion in 

funding for unknown objectives from anonymous sources in China, Russia, Qatar, and Saudi Arabia.
For further information

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• White House Joint Committee on the Research Environment: JCORE@ostp.eop.gov

• Email academia@fbi.gov or contact your local FBI field office

• Contact your Federal funding agency 
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