Georgia Tech is committed to maintaining an open environment to foster research discoveries and innovation that benefit our community and the world. Our international partnerships play a crucial role in our mission, and we are proud to connect students, faculty, and research collaborators around the world.

While an open, collaborative environment is supported at Georgia Tech, we must also protect your research and development against foreign government interference and misappropriation. Several federal mandates, including the implementation of National Security Presidential Memorandum-33, are informing ongoing changes in Institute systems, policies, and procedures. A collection of resources from federal agencies and national societies are also available.

If you are a Georgia Tech employee working directly on U.S. federally funded sponsored research projects and travel internationally, the following important updates apply to you.

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Why is protecting your research important?

There is an increasing need to protect U.S. federally funded scientific research from undue foreign influence, including exploitation of the open university research environment and intellectual property theft. Federal initiatives around research compliance including NSPM-33, the CHIPS (Creating Helpful Incentives to Produce Semiconductors) and Science Act, and CMMC (Cybersecurity Maturity Model Certification) are working to address this need.

Research is led by principal investigators (PIs). Their ideas engage students and other researchers, and the PIs secure grants to help fund and support their research. Collaborations can also be established with institutions outside of Georgia Tech and the United States.

The centrality of PIs to the research enterprise places them most at risk of foreign interference or influence as well as U.S. government investigation, and their role in risk assessment and management is central.

PIs are responsible for continuously ensuring that all members of their research groups understand the norms and expectations regarding the sharing of information outside the group.

To support researchers in this work, Georgia Tech aims to:

  • Maintain an open environment to foster research discoveries and innovation while providing guidelines for protecting your research
  • Provide the information needed for compliance
  • Minimize risks


What is foreign influence?

The U.S. Government, including members of Congress and federal agencies, has expressed serious concerns regarding inappropriate influence by foreign entities, government, or individuals on U.S. institutions and researchers. Concerns of foreign influence are:

  • Inappropriate or inadvertent sharing of proprietary information, intellectual property, or data of grant applications, unpublished research, or technologies.
  • Sharing of confidential information by researchers serving as peer reviewers of grant applications.
  • Failure of researchers to disclose substantial support from outside activities or foreign organizations in grant application Current & Pending forms. There are concerns regarding the failure to follow federal agency requirements to disclose foreign components or foreign collaborations in progress reports or ongoing awards.

Several federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding.

The Office of Science and Technology Policy (OSTP) issued guidance regarding government-wide foreign interest and activity disclosure requirements in accordance with National Security Presidential Memorandum (NSPM-33): Presidential Memorandum on United States Government-Supported Research and National Security.


NSPM-33: What is it and how does it impact you?

The Presidential Memorandum on United States Government-Supported Research and Development National Security Policy, more commonly known as National Security Presidential Memorandum 33 (NSPM-33), was released at the end of the last presidential administration. A year later, the National Science and Technology Council issued guidance for NSPM-33’s implementation. This guidance includes several mandatory federal requirements designed to enhance the protections of U.S. Government-supported research and development (R&D) against foreign government interference and misappropriations by maintaining an open environment fostering research discoveries and innovation that benefit the United States and the world. These mandatory requirements will provide consistency while preserving the open and collaborative nature of the U.S. research enterprise through enhanced research security techniques focused on responsibilities, transparency, and equity.

NSPM-33 requires all federal research funding agencies to strengthen and standardize disclosure requirements for federally funded awards. NSPM-33 mandates the establishment of research security programs at research institutions receiving federal funds. NSPM-33 will also require oversight and enforcement activity in the form of administrative actions as well as civil or criminal penalties.

Why is NSPM-33 required?

There is an increasing need to protect U.S. funded scientific research from undue foreign influence, including exploitation of the open university research environment and intellectual property theft. NSPM-33 applies to research organizations awarded more than $50 million per year in total federal research funding.

What are the goals of NSPM-33?

  • To protect America’s national security while promoting openness in the research community
  • To ensure that policies do not fuel xenophobia or prejudice

Georgia Tech has established a working group to address the key NSPM-33 areas.

The working group's objective is to customize solutions for the Georgia Tech environment that will protect the researcher, without increasing bureaucracy. Four subgroups focus on different compliance requirements:

  • Disclosure Requirements, Standardization and Consequences for Violation – many disclosure requirements are being standardized across government agencies; therefore, the Georgia Tech working group is evaluating agency guidance as it evolves.
  • Digital Persistent Identifiers – registration for an ORCID iD has been identified as the solution for this requirement. All Georgia Tech researchers are recommended to register and obtain an ORCID iD and connect it to Georgia Tech.
  • Research Security Program: Foreign Travel Security, Research Security Training and Export Control Training – Georgia Tech’s working group has been working closely with GTRI to design processes and training for the Georgia Tech federally funded researcher. This includes the following areas: foreign travel security, research security export control, insider threat awareness, cybersecurity, etc.
  • Research Security Program: Cybersecurity



For Georgia Tech researchers, one easy step toward compliance with NSPM-33 is registering with ORCID to receive a digital identifier (an ORCID iD).

ORCID is a non-profit organization supported by a global community of member organizations, including research institutions, publishers, funders, professional associations, service providers, and other stakeholders in the research ecosystem.

You can access ORCID training videos by logging into Georgia Tech's Learning Management System using SSO, then search using the word "ORCID" or under the "How To" category.


Updated Foreign Travel Requirements

All Georgia Tech employees working directly on U.S. federally funded sponsored research projects and traveling overseas on official business will continue to follow Georgia Tech policy by completing the WorkDay Spend Authorization.

When completing the WorkDay Spend Authorization, the traveler answers a series of questions.

What’s NEW?

NEW QUESTION on Form: asks if you are traveling to either an Office of Foreign Assets Control(OFAC) embargoed country:or countries identified in 22 CFR 126.1(d)(1) & (d)(2) Tables 1 & 2.

  • If the answer is NO, no further action is required.
  • If the answer is YES, you will be required to complete a foreign travel notification to Georgia Tech Research Security (RS) 30 days prior to your departure.

Upon completion of the Georgia Tech RS notification, a RS member will provide a valuable safety and security briefing prior to your departure in the ticket. No additional correspondence is required.

This information will be documented and retained for future self-reviews by the Institute and inspections by the U.S. Government.

NOTE: All Georgia Tech personnel who have a security clearance are required to report ALL work and personal foreign travel regardless of country.

Personal Foreign Travel – Georgia Tech personnel who do not possess a clearance and are using personal funds for travel (i.e. vacation) are not required – but are highly encouraged – to report foreign travel to assist in travel safety, emergency evacuation, or other State Department assistance programs. This form (accessible only by first logging into the campus VPN) can be completed for reporting.

If you have questions or need clarification on the requirements, please email

More information about travel tips and requirements can be found here.


Changes to Disclosures

Researchers submitting proposals to federal sponsors will need to certify the accuracy and completeness of the below information:<

  • Biosketch
  • Other Support
  • Current and Pending
  • Keeping your information updated in SciENcv assists you in complying with this requirement.

Learn how to create an NSF-approved biosketch with SCiENcv.

Learn more about Sponsor Disclosure Requirements. 


Insider Threat Program and Reporting

Georgia Tech is designated by the U.S. Department of Defense a Cleared Defense Contractor, which gives clearance to receive and store certain classified and sensitive information for the purpose of providing critical services and innovative solutions to various military defense and national security projects.

Learn more about the policy.

Report a potential insider threat.


Foreign Talent Recruitment Programs — Georgia Tech’s Policy and Reporting

As a Georgia Tech researcher, it’s essential to understand foreign talent recruitment programs and reporting required by federal agencies.

Many countries use talent recruitment programs for legitimate purposes of attracting researchers in certain fields, and many programs utilize legitimate means of attracting talent, including offering research fellowships and grants as an incentive to physically relocate.

However, there is a distinction between “foreign talent recruitment programs” and “malign foreign talent recruitment programs.”

Though any country can sponsor a foreign talent recruitment program, the U.S. Government is particularly concerned with programs affiliated with China, North Korea, Russia, and Iran.

The U.S. Government is concerned that participation in a foreign talent recruitment program could lead to undisclosed conflicts of interest, inappropriate transfer of federally funded research, export to control violations, and intellectual property theft.

Note – a researcher may be participating in a foreign talent recruitment program because of the activities that they are performing, regardless of whether their activities are associated with a formal program name.


All Georgia Tech employees participating in foreign talent recruitment programs must disclose their participation to Georgia Tech. All covered individuals must also disclose their participation to the sponsor.

Georgia Tech prohibits any covered individual from participating in a malign foreign talent recruitment program and requires all covered individuals to comply with individual sponsor policies regarding foreign talent recruitment programs and malign foreign talent recruitment programs.

  • The CHIPS and Science Act of 2022 requires that covered individuals, including senior and key personnel, certify that they are not part of a malign foreign talent recruitment program in the proposal submission and annually thereafter. The CHIPS and Science Act also prohibits federal agencies from making research and development awards for any proposal in which a covered individual is participating in a malign foreign talent recruitment program.
  • In 2023 the Department of Defense issued Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education stating that “Beginning August 9, 2024, the DoD is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program or to a proposing institution that does not have a policy addressing malign foreign talent programs under Section 10632 of the CHIPS and Science Act of 2022.
  • Beginning May 2024, individuals identified as senior/key personnel on any National Science Foundation (NSF) award must certify that the individual is not a party to a malign foreign talent recruitment program before proposal submission and annually thereafter. Other federal agencies will adopt this certification requirement over time.


Definition of a Covered individual

  • contributes in substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a federal research agency; and
  • is designated as a covered individual by the federal research agency concerned – CHIPS and Science Act

Definition of a Foreign Talent Recruitment Program

Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position).

Definition of a Malign Foreign Talent Recruitment Program

Includes any foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology unethically or unlawfully through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.

Source: Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs


Contact if you have questions about reporting, or Research Security if you have questions about whether a program you are currently participating in or are considering participating in could be considered a foreign talent recruitment program.

Disclosure to federal agencies and Georgia Tech is critical concerning foreign talent recruitment programs, and researchers should err on the side of transparency.