U.S. government agencies and major federal sponsors of research at Brown closely scrutinize whether engagements with foreign entities and individuals, particularly in the form of research funding, gifts and collaboration, are in compliance with laws and regulations that govern these engagements. Their concerns focus on national security and the potential for valuable intellectual property and other research resources to be inappropriately and sometimes illegally transferred to foreign nations. This is an evolving area of concern and focus for the U.S. government.

Brown Values International Collaboration and Scholarship

Brown remains dedicated to supporting its faculty, staff and students in this time of heightened interest in global research activities while ensuring compliance with all U.S. regulations. Brown is also deeply committed to preserving and protecting the freedom of research and to maintaining a research environment that is open and that promotes the free exchange of research results. 

• Openness in Research Policy

Sponsor Requests for Citizenship Information

Brown University does not share citizenship information with sponsors, unless it is a condition of eligibility to apply for funding (e.g., NIH fellowships). Providing citizenship information to a sponsor for pre-approval of research participants may violate Brown’s Openness in Research policy and may jeopardize the Fundamental Research status of the research project. It is also contrary to Brown's statement on Terms and Conditions in Sponsored Research Agreements. Only the Brown principal investigator (PI) has the authority to identify and hire project personnel. This is to protect the PI's freedom to manage the project as they deem appropriate and prevent potential discriminatory practices. 

Given Brown generally does not accept agreements or contracts that give sponsors the right to review and pre-approve research participation based on citizenship, you should not receive any requests for sharing of citizenship information from sponsoring agencies. In the event that you do receive such a request from your program officer, contact or refer them to Sponsored Projects for assistance.

Before engaging in an international collaboration, you need to determine if export licenses are required and verify that the foreign individual or organization is not a blocked or sanctioned entity. It’s also important that you disclose relevant international collaborations to research sponsors and when prompted as part of the University's conflict of interest and conflict of commitment disclosure processes and policies. Below are a few key areas of compliance to keep in mind when engaging in international research collaboration.

Identify Sources of Support

Federal sponsors are focusing more closely on the full disclosure of project support than in years past. It is critically important that complete and accurate information about research support and academic and professional appointments and affiliations are included in all grant and contract proposals whenever required. This requirement will vary from sponsor to sponsor, so be sure to closely review the rules.

• DOD Support Disclosure Requirement
• DOE Support Disclosure Requirement
• NASA Support Disclosure Requirement
• NIH Other Support Disclosure Requirement
• NSF Support Disclosure Requirement

Disclosing Foreign Components and Collaborations

Federal agencies such as the National Institutes of Health (NIH) and National Science Foundation (NSF) have expressed heightened concern about the lack of disclosure of collaborations with, and/or funding by, foreign entities — including foreign governments and foreign institutions of higher education — and have issued specific reporting requirements.

• NIH Requirements for Disclosure of Foreign Components
• NSF Malign Foreign Talent Recruitment Program Requirements

Disclose Conflicts of Interest

You must disclose any and all conflicts of interest and outside professional activities in accordance with institutional policies.

Comply with Export Controls

You must comply with all export control policies and regulations. Contact Brown’s Export Control team as early in the process as possible.

Prepare for International Travel

Prepare for research-related international travel with guidance from Export Control, the Office of Information Technology (OIT), Global Brown and other partners across campus.

Report Gifts and Sponsored Research Funds

Make sure to work with the appropriate office when you receive gifts or sponsored research funds to ensure that institutional review and vetting is conducted. If you are contacted by a company, organization or individual regarding a potential gift (monetary or in-kind) or offer of collaboration, involve the University as early as possible in these discussions.

Disclose Intellectual Property

You must disclose intellectual property in accordance with institutional policy. Include all inventors, regardless of whether the inventors are affiliated with Brown or the funding supporting the work is foreign or domestic.

Comply with University Signatory Authority Requirements.

When conducting research at Brown you cannot sign any type of partnership agreement, data sharing agreement or material transfer agreement — or otherwise commit or implicate the University or its resources through legal agreements or documents, whether binding or nonbinding — unless authorized to do so. This includes but is not limited to: letters of intent, collaboration agreements, sponsored research agreements, nondisclosure agreements (NDAs), confidential disclosure agreements (CDAs) and license agreements.