Research, Innovation & Impact

The U.S. Department of Energy (DOE) has implemented Order 486.1 “to ensure the continued flow of scientific and technical information" consistent with the DOE’s broad scientific mission while also:

• Ensuring protection of U.S. competitive and national security interests and DOE program objectives.
• Preventing potential conflicts of interest (e.g., financial interests, conflicts of commitment and outside employment) that may undermine the DOE research enterprise.
• Limiting unauthorized transfers of scientific and technical information.

As such, participation in a foreign government sponsored talent recruitment program of a foreign country of risk is prohibited for DOE employees and for MU employees with DOE awards. Disclosure of pending and current participation is required. Additionally, disclosure to MU and receipt of approval from MU is required through the conflict of interest disclosure process. Exemptions for participation in such other foreign government sponsored or affiliated activities may be granted by DOE. If you are in this scenario, Research Security and Compliance will facilitate that approval. Exemptions are not permitted for participation in such foreign government sponsored talent recruitment programs.

Definitions

Foreign government sponsored talent recruitment program

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, and whether having a full-time or part-time position)

• Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods and intellectual property to further the military modernization goals and/or economic goals of a foreign government. 
• Many, but not all, programs aim to incentivize the targeted individual to physically relocate to the foreign state for the above purpose. 
• Some programs allow for or encourage continued employment at U.S. research facilities or receipt of federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to U.S. entities. 
• Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation or other types or remuneration or consideration, including in-kind compensation.

Foreign country of risk

Any foreign country determined to be of risk, following consideration of, but not limited to the: 

• Office of the Director of National Intelligence WorldWide Threat Assessment.
• National Counterintelligence Strategy of the United States of America.
• Under Secretary for Science in consultation with the Under Secretary of Energy.
• Under Secretary for Nuclear Security.
• Office of Intelligence and Counterintelligence. 

As of August 2021, these countries are the People's Republic of China, Islamic Republic of Iran, the Democratic People's Republic of Korea and the Russian Federation.

Other foreign government sponsored or affiliated activities

Includes the following activities directly or indirectly involving a foreign country of risk entity as defined below: 

• Employment.
   
• Other support, contractual or otherwise, direct and indirect, including current and pending private and public sources of funding or income, both foreign and domestic. 
  • For researchers, other support includes all foreign country of risk entity resources made available, directly or indirectly, to a researcher in support of and/or related to all of their professional R&D efforts, including resources provided directly to the individual rather than through the research institution, and regardless of whether or not they have monetary value (e.g., even if the support received is only in-kind, such as office/laboratory space, equipment, supplies or employees). 
  • This includes resource and/pr financial support from all foreign and domestic entities, including but not limited to, gifts, financial support for laboratory personnel and participation of student and visiting researchers supported by other sources of funding. This further includes compensation, for example, current or promises of future: grants, awards, funding, scholarship, appointment, sabbatical, travel, university directed funding and honoraria. 
     
• Current or pending participation in, or applications to programs (e.g., grant programs) sponsored by foreign governments, instrumentalities or entities, if not a foreign government sponsored talent recruitment program, as defined. Associated contracts, upon request by DOE, must be disclosed, in addition to the fact of participation. 
   
• Positions and appointments, both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic, professional or institutional appointments whether or not remuneration is received, and whether full-time, part-time or voluntary (including adjunct, visiting or honorary). 
   
• The following, considered alone, are not included in this definition: 
  • In-kind support under a fundamental research collaboration for the sole purpose of co-authorship to be made publicly available.
  • Support related specifically to implementing a DOE program-sponsored international collaboration project and within the scope of a DOE-level or U.S. government-level bilateral or multilateral international agreement.