Assessing and Mitigating Risk

Updated September 4, 2024

Federal regulations are subject to change, sometimes with very short notice. Return to this page periodically to confirm your activity is aligned with current requirements. You may also contact research-compliance-help@mit.edu or your contract administrator with any questions.

  • Participating in predatory talent recruitment programs could affect your eligibility for federal research funding. Participation is specifically prohibited by certain U.S. government research agencies. This section is designed to help you assess whether a program you may have been approached by is ok or has the characteristics of a ‘malign’ or predatory talent recruitment program.

    In general

    Talent recruitment programs, such as NIH or NSF internships and fellowships, can advance your academic career. Acceptable talent programs are fully transparent and encourage collaboration and novel research. Any talent program you consider should:

    • Place no restrictions on publications
    • Grant IP and other proprietary rights in accordance with US laws
    • Engage with you through an agreement or contract with MIT

    Countries of Concern (Presenting Added Risk)

    Federal research agencies prohibit funds going to individuals in talent recruitment programs operated by any government-identified Countries of Concern. For example, the 2022 CHIPS and Science Act prohibits you from receiving federal research grants if you participate in a malign foreign talent recruitment program. These programs are designed to unethically or unlawfully acquire U.S. scientific-funded research or technology and are not focused on collaboration on novel, publishable research.

    Red flags:

    • Focused on replicating your U.S. funded research programs
    • Entering into a contract with you, not MIT
    • Asking you not to disclose the engagement to MIT or U.S. sponsors of your research

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor. It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: Disclose remuneration of at least US $5,000 that you receive in a 12 month period directly from the entity (i.e. MIT is not a party to any agreement with the entity and MIT is not administering the funding).
    • OPA: Report any participation in a talent program that is not through an agreement with MIT.
    • Sponsor disclosures: Disclose to MIT as required by sponsor your participation in any foreign talent recruitment program. 

    Additional resources

  • As part of their normal scholarly activities, MIT researchers engage in many informal collaborations and communications with colleagues around the world, resulting from meeting colleagues at conferences or meetings. Exchanging discussions and ideas over email is an example of an informal collaboration. Informal collaborations have no formal written agreement or contract, required deliverables, or funds exchanged. Collaborating with researchers at organizations on government watch lists can expose the investigator to risks.

    In general

    MIT values academic communication and cooperation with international colleagues. However, even informal collaborations need to follow research security, export control and other laws. MIT has created the Informal International Collaborations tool (IIC) to assess the risks of a potential informal collaboration regardless of who the collaboration may be with.

    Countries of Concern (Presenting Added Risk)

    Informal collaborations on sensitive technologies or with someone on a government watch list could expose you and your research to risks. Use the Informal International Collaborations tool (IIC) to assess the risks of engaging in these activities with colleagues outside the U.S.  An increasing number of Chinese institutions with strong ties to the People’s Liberation Army and institutions those from other Countries of Concern are being identified on watch lists, which increases the risk of these collaborations. As a result, you may not be able to transfer certain items to restricted parties, making the collaboration impractical. Collaborating with parties looked at suspiciously by the US government may also impact applications for federal funding. Using the IIC tool is critical if you are considering an informal collaboration with anyone at one of these entities.

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor. It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: No disclosure required if no remuneration is received by you directly.
    • OPA: Report any informal international collaborations in the OPA form.
    • Sponsor disclosures: Disclose informal collaborations (which include exchanges of staff, materials, data, funding of any kind or value, or other significant activity which could result in joint authorship) in proposals and reports. 

    Additional resources

  • Knowing who we are inviting to our campus and into our labs helps protect our students, researchers, research results, access to labs, and intellectual property against improper exposure and use. Lab staff should feel comfortable in the lab as they perform their research or other duties and not feel wary of unknown people in their lab space.

    In general

    MIT researchers are free to invite their professional colleagues to visit the MIT campus. Increasingly, that freedom must be balanced with knowing whether the person we are inviting comes from a high risk country.

    Countries of Concern (Presenting Added Risk)

    It is advisable that MIT not appoint as postdocs or visiting researchers individuals who are known to be members of China’s armed forces, employed by Chinese military and security institutions, or employed by China’s national defense universities.

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor.  It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: Disclosure in COI is not required unless you were paid directly at least US $5,000 to host the students.
    • OPA: Reporting as an OPA is required if you were paid directly any amount to serve as a host.
    • Sponsor disclosures: If your visitor is contributing to your MIT research, contact your contract administrator in RAS to find out what disclosures are required based on research funding and sponsor requirements.

    Additional resources

  • All gifts to individual researchers and to MIT must comply with MIT’s general policies, principles, and processes for soliciting and accepting gifts. Notify the Gift Acceptance Committee through the recording secretary’s office before accepting any gifts from entities which are on restricted entities lists.

    In general

    Per MIT’s Financial Conflicts of Interest in Research policy, Investigators may not accept gifts, in support of the Investigator’s Institutional Responsibilities from a for-profit privately-held Related Entity.  However, an investigator may accept a gift or in-kind gift in support of the Investigator’s Institutional Responsibilities from a publicly-held or non-profit Related Entity, with approval from their department head and COI office.  

    Gifts (including in-kind) are acceptable for use in research if they are not from an entity in which an Investigator has a significant financial interest as long as it complies with MIT’s general policies, principles, and processes for soliciting and accepting gifts. 

    Gifts from individuals who are on the Specially Designated Nationals And Blocked Persons List are not allowed.

    Countries of Concern (Presenting Added Risk)

    Notify the Gift Acceptance Committee before accepting any gifts directly or indirectly, from or involving these entities.

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor. It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

  • In general

    All MIT norms and policies apply to work that MIT people do and actions that they take when traveling outside the U.S. on MIT-related travel. 

    When planning your MIT-related travel outside the U.S.: 

    • You are strongly encouraged to inform your department, lab, or center head prior to booking a trip.
      • Please note that as soon as NSPM-33 requirements are fully implemented, we anticipate that government regulations will require you to get department head approval prior to booking your trip if you are funded by any of the U.S. federal agencies.
    • Register MIT-related travel in the Institute’s Travel Registry.
    • Contact Research Administration Services to learn more about allowable costs if traveling on a federally funded award.

    Countries of Concern (Presenting Added Risk)

    Traveling to elevated-risk countries can raise issues related to protection of electronic devices and data, as well as export control, customs and visa considerations.   

    • Before traveling to countries of concern, define the purpose of your visit and review with MIT Export Control.
    • Do not bring your primary computer and cell phone. Contact IS&T about getting a temporary computer and phone to bring with you, and work with your department administrator to secure any other electronic devices.

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor. It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: Disclose any travel expenses of at least US $5,000 or more reimbursed directly to you in a 12 month period (not administered by MIT), if your research is funded by NIH, DOE or NASA.
    • OPA: Report international external engagements using the international section of the OPA form.
    • Sponsor disclosures: Contact your contract administrator in RAS to find out what disclosures are required.

    Additional resources

  • In general

    Before giving lectures in executive and professional education programs, determine whether the organization or (if the lecture is not open to the public) the participating individuals are on any of the U.S. government’s prohibited lists.

    Countries of Concern (Presenting Added Risk)

    Executive and professional education programs generally do not raise the kind of concerns that might arise in research engagements with countries of concern. Knowledge and information provided in an educational setting, including classes and lectures that are open to a general audience, are not subject to U.S. export control restrictions, but faculty should only present information that is already available in the public domain. 

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor.  It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: Disclose remuneration of at least US $5,000 that you receive directly from the entity (i.e. MIT is not a party to any agreement with the entity and MIT is not administering the funding).
    • OPA: Report any external engagements, even if in the U.S. 
    • Sponsor disclosures: Contact your contract administrator in RAS to find out what disclosures are required.

    Additional resources

  • A central component of MIT’s graduate education is the opportunity for students to learn from faculty. Faculty should not hesitate to mentor students or postdocs or to recommend them for positions. 

    In general

    Any recommendation should conform to MIT values and contain a truthful and complete accounting of how the faculty member knows the candidate, as well as an assessment of the candidate’s abilities. 

    Faculty should not write letters of recommendation for non-MIT students in programs (such as tutoring programs) in which they have been paid to teach with a quid pro quo that they write such letters. 

    Countries of Concern (Presenting Added Risk)

    Though faculty can recommend candidates for positions in countries of concern, if they are known to them and have engaged sufficiently to support their candidacy for a position, they should not play an organizational or administrative role in programs that seek to channel graduates into non-academic jobs in those countries.

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor. It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: Disclose if you received payment directly of at least US $5,000 or more for these activities.
    • OPA: Reporting in OPA is required if you engaged in this activity through a contract or some other agreement, even if not compensated.
    • Sponsor disclosures: Contact your contract administrator in RAS to find out what disclosures are required.

    Additional resources

  • In general

    While on leave or sabbatical, you may have increased opportunities to engage with entities outside of MIT. However, accepting compensation from or devoting significant time to these entities can create a conflict of interest or commitment.

    Countries of Concern (Presenting Added Risk)

    Even while on leave or sabbatical, you still have access to MIT resources. Contact MIT Export Control and MIT Research Compliance before engaging with any countries of concern.

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor. It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    Additional resources

  • Faculty members must prioritize obligations and commitments to MIT before considering other appointments at U.S. or foreign institutions:

    • Continuing or regular professorships: Normally not allowed. Exceptions may be considered in rare cases.
    • Temporary or visiting appointments: Possible during periods of sabbatical or other leave from MIT.

    In general

    Before accepting an external continuing or temporary appointment, consult: 

    • Department head and dean: MIT Policies and Procedures 4.3 requires permission from your dean before accepting an external appointment. Your department head or dean may consult with the provost.
    • MIT Export Control: If the appointment is at a foreign university, the export control team can screen the organization against U.S. sanctions lists and advise on other risks. 
    • Personal legal representation: If the appointment is at a foreign university, seek advice on the impact of the university’s policies and any local rules governing academic activities, intellectual property and employment. Request translations of any policies or agreements if they are written in a language for which you are not fluent.

    Even after consultation, you maintain full responsibility for your actions. Avoid ethical, legal, financial, and other conflicts of interest and ensure that your activities and interests do not conflict with your obligations to MIT or its welfare. 

    Countries of Concern (Presenting Added Risk)

    If the university is in China, Russia, North Korea or Iran, then contact research-compliance-help@mit.edu to determine whether the appointment could be considered participation in a malign foreign talent recruitment program.

    Disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor. It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: Disclose compensation of at least $5,000.
    • OPA: Report all appointments and affiliations at other universities, domestic and foreign.
    • Sponsor disclosures: Disclose academic appointments at other universities to sponsors in accordance with agency-specific guidance, particularly if the appointment is at a foreign university. 

    Additional Resources

  • In general

    If your research sponsors also compensate you for lectures, teaching engagements, or review panels, this may create a conflict of interest.

    Countries of Concern (Presenting Added Risk)

    If engaging with a university or organization in a country of concern, contact MIT Export Control and Research Compliance to assess whether the organization is on any sanctions lists or part of a malign foreign talents program.

    When teaching or lecturing abroad, or to an international audience, only present on information in the public domain.

    Required disclosures

    Disclosing conflicts of interest (COI) or outside professional activities (OPA) to MIT is not a disclosure to the sponsor.  It is the responsibility of the individual researcher to provide details of such engagements to the sponsor.

    • COI: Disclose if you received at least US $5,000 in a 12 month period directly from the entity for delivering a lecture, teaching or serving on a review panel.
    • OPA: Report any external engagements, even if in the U.S.
    • Sponsor disclosures: Contact your contract administrator in RAS to find out what disclosures are required.

    Additional resources