Foreign Talent Recruitment Programs

Many countries sponsor talent recruitment programs for legitimate purposes of attracting researchers in targeted fields, and 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. “Malign foreign talent recruitment” programs include any foreign-state-sponsored attempt to unethically or unlawfully acquire U.S. scientific-funded research or technology 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.

UNC Charlotte researchers are advised that participation in an FTRP must be disclosed to the university in Niner Research, and to federal sponsors in Biosketches and Current & Pending/Other Support, as applicable.  Federal agencies consider this disclosure in determining funding.  Failure to disclose participation in an FTRP has resulted in legal action by the U.S. government against researchers who are engaged in federally-sponsored research. Additionally, UNC Charlotte prohibits participation in Malign Foreign Talent Recruitment Programs by researchers. Researchers are encouraged to carefully review all agreements and thoroughly vet all arrangements to ensure that they are aware of any participation in a talent program or MFTRP.

Foreign Talent Recruitment Program (FTRP) Definition

A foreign talent recruitment program is any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.

A foreign talent recruitment program does not include the following international collaboration activities, so long as the activity is not funded, organized, or managed by an academic institution or a foreign talent recruitment program on the lists in Tables 1 and 2, linked below.

  1. Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law; 
  2. Participating in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law; 
  3. Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student’s request; and 
  4. Engaging in the following international activities: 

a) Activities that are partly sponsored or otherwise supported by the United States such as serving as a government appointee to the board of a joint scientific fund (e.g., the U.S.- Israel Binational Industrial Research and Development Foundation); providing advice to or otherwise participating in international technical organizations, multilateral scientific organizations, and standards setting bodies (e.g., the International Telecommunications Union, Intergovernmental Panel on Climate Change, etc.); participating in a Fulbright Commission program funded in whole or in part by a host country government; or other routine international scientific exchanges and interactions such as providing invited lectures or participating in international peer review panels. 

b) Involvement in national or international academies or professional societies that produce publications in the open scientific literature that are not in conflict with the interests of the federal research agency (e.g., membership in the Pontifical Academy of Sciences or The Royal Society). 

c) Taking a sabbatical, serving as a visiting scholar, or engaging in continuing education activities such as receiving a doctorate or professional certification at an institution of higher education (e.g., the University of Oxford, McGill University) that are not in conflict with the interests of the federal research agency. 

d) Receiving awards for research and development which serve to enhance the prestige of the federal research agency (e.g., the Nobel Prize). 

e) Other international activities determined appropriate by the federal research agency head or designee. 

Recognizing Malign Foreign Talent Recruitment Programs (MFTRP)

A foreign talent program is considered “malign” when it offers cash or in-kind compensation (complimentary foreign travel, honorary appointments, promised future compensation, research funding, etc.), in exchange for one of the following:

  • Engaging in the unauthorized transfer of intellectual property, materials, data, or other nonpublic information;
  • Recruiting or training other talent recruitment program members, circumventing merit-based processes;
  • Establishing a laboratory or company or accepting a faculty position or other employment in a foreign country in violation of terms and conditions of a Federal research award;
  • Applying for and receiving research funding from the foreign institution’s government funding agencies with the foreign institution as the awardee, without disclosure to and approval from UNC Charlotte;
  • Attributing awards, patents, publications, and projects to the foreign institution, even if conducted under a Federal research award, omitting UNC Charlotte and/or the Federal funding agency;

OR is characterized by contracts or agreements with:

  • Oppressive termination clauses;
  • Non-disclosure requirements; or 
  • Duplication of effort under Federal awards or conflicts of commitment with Federal awards

AND is sponsored by:

  • a foreign country of concern or an entity based in a foreign country of concern,
  • an academic institution on Table 1; or
  • a foreign talent recruitment program on Table 2.

As of May 1, 2024, current countries of concern are: China, Russia Federation, North Korea and Iran. This list will be updated as new information becomes available.

UNC Charlotte prohibits Malign Foreign Talent Recruitment Program participation effective May 20, 2024. Researchers are encouraged to carefully review all agreements and thoroughly vet all arrangements to ensure that they are aware of any participation in a talent program or MFTRP.

Foreign Talent Programs And Entities that Pose a Threat to National Security Interests of the United States

Key contacts

If you suspect you have been contacted by or become associated with a malign foreign talent program, contact the UNC Charlotte Office of Research Protections and Integrity. They can share information on reporting requirements and how participation may affect current and future federal funding.

  • Sherry Loyd, Associate Director, Research Protections and Integrity: 704-687-8270