International Collaboration

For the most recent developments shared with the Caltech Community, please refer to our Newsletter.

The Council on Governmental Relations (COGR) also publishes a monthly update, which is very informative.

Caltech utilizes research security training available in the CITI training system, including: Research Security or Research Security, Update, Conflicts of Interest, Research Integrity, Responsible Conduct of Interest and Export Compliance Awareness Training. Access the training through access.caltech.edu under Self Service > Research Ethics Education (CITI).

The Caltech Research Compliance Training Matrix allows you to search by agency and determine what training is required, when it is required, and how often it must be completed.

Each federal agency has specific reporting requirements for Senior and Key research personnel to provide accurate and complete Biosketches, Other Support, Collaborations/Foreign Components, and Facilities as part of their proposal/appication for funding and at proscribed periods after award. The Biosketch and Other Support are typically provided in SciENcv. To easily create your SciENcv disclosures, you should have an ORCiD Open Researcher and Contributor ID.

The agency requirements can be found here: Transparency in Research: Federal Agency Disclosure Requirements. As with the training webpage, the requirements are searchable by agency. IT IS ESSENTIAL THAT ALL OTHER SUPPORT be reported as accurately as possible. Caltech has a policy regarding Disclosure of Other Support and has created the Biosketch and Other Support Application to assist you in collecting data.

The Office of Research Security (ORS) works with the Office of Sponsored Research (OSR) to assist you in the review and submission of proposals, and the negotiation, and acceptance of awards, for research, training, and other sponsored programs. OSR and ORS can help you with questions about the forms and about agency requirements.

It is essential to disclose all forms of research support, especially from foreign sources (including gifts, scholarships and fellowships). When there is a question about a possible conflict of interest or a conflict of commitment, a decision to err on the side of disclosure will protect both the investigator and the Institute. More information may be found at Conflicts of Interest.

• All researchers, including Faculty, Staff, Postdocs and Graduate Students must disclose covered outside activities and financial interests:
  • at least annually, and
  • within 30 days of engaging in any new activities or acquire any new financial interests which could be perceived as being a conflict
• Senior and Key Personnel must
  • identify possible COI at the time of application (Use the Compliance Page in PAM)
  • report travel paid or reimbursed by a third party with 30 days of completing the trip
  • If the sponsor is DOE, then potential CoI or CoC must be disclosed and a proposed management plan created prior to submission of the application.

Use Disclosure of Financial Interests and Commitments (DFIC) Application through access.caltech.edu for all disclosures to Caltech.

Note that changes in federal agency requirements mean Investigators may need to report outside activities to sponsors, as well. See agency-specific requirements for details.

Send questions to [email protected]./research-security/conflicts-interest

Consistent with NSPM-33, all researchers are required to disclose all commitments to, agreements with or contracts associated with participation in programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs. In addition to disclosure, Caltech requires a copy of the agreement be attached for review.

Further, if individuals receive direct or indirect support that is funded by a foreign government-sponsored talent recruitment program, even where the support is provided through an intermediary and does not require membership in the foreign government-sponsored talent recruitment program, that support must be disclosed. Individuals must also report other foreign government sponsored or affiliated activities.

In accordance with 42 USC § 19232, individuals are prohibited from being a party in a malign foreign talent recruitment program.

As part of an international collaboration or other research-related or professional activity, you may be asked to sign an agreement that includes provisions pertaining to intellectual property (IP), possibly including, but not limited to, rights in inventions, patents, software, or copyright. Such IP terms should be reviewed by Caltech's Office of Technology Transfer and Corporate Partnerships (OTTCP) and may need to be renegotiated to be compatible with your IP obligations to Caltech, whether the agreement is with a domestic or foreign entity. Note that commitments of IP or agreement to confidentiality clauses may be associated with a Foreign Talent Recruitment Program.

The mission of the California Institute of Technology is to expand human knowledge and benefit society through research integrated with education. In support of its mission, Caltech takes its commitment to openness in research very seriously. Caltech's policy (Openness in Research, Export Compliance Policy) is that the results of all research performed by faculty, staff or students will be free from restrictions on publication or dissemination.

Caltech's fundamental research "safe harbor" generally applies only to work at or for Caltech in the U.S. These protections do not always apply when activities cross international borders. Researchers should request a review of their activities for EAR or ITAR compliance when they plan research for Caltech outside the U.S. or the research involves export-controlled technology transfers to foreign persons in the U.S. (deemed exports).

Export Control regulations are likely to apply to the following activities:

• Use of export-controlled information or items in your collaboration with foreign parties
• Use of Controlled Unclassified Information (CUI) or restricted information
• International collaborations that include JPL involvement
• Foreign Talent Program engagements
• Traveling internationally and attending conferences
• Traveling to sensitive, embargoed or sanctioned countries
• Participating in international collaborations
• Use of proprietary data subject to a confidentiality or nondisclosure agreement
• Hosting international visitors, or
• Shipping items (software, hardware or technical data) internationally

Researchers may be held personally liable for violating export control laws. The Export Compliance Office will assist you with any questions regarding export control requirements in a particular country or licensing requirements for specific activities.

Please visit Export Compliance and International Travel page for additional information and guidance.

Federal sponsors are becoming increasingly concerned about foreign collaborations giving rise to publications funded by the US as evidenced by several US Government reports issued citing US co-authorship or co-funding with Chinese co-authors as evidence of undue foreign influence: DoD/DoW- Fox in the Henhouse | Select Committee on the CCP, DoE- Containment Breach: US DoE Failures in Research Security and Protecting Taxpayer-Funded Research from Foreign Exploitation and NASA- Research Security for America's Future in Space: NASA's Enforcement of the Wolf Amendment.

Caltech has developed this Collaboration and Publication and Reporting Guidance for Caltech Researchers to aid you in navigating collaborations and co-authorships.

Caltech fosters an environment that encourages collaboration and the exchange of ideas. The Institute supports various types of visitors, including external affiliates, guest collaborators, volunteers, and academic visitors such as visitors, visiting associates, and visiting professors. To promote compliance with Caltech policies and legal requirements affecting its research and business activities, Caltech uses the Visitor Access Request (VAR) application to review and approve visitor requests before they begin their activities.

Applications from Visiting Students and Postdocs (e.g., SURF, Visiting Undergraduates, Visiting Graduate Students or Visiting Postdocs) are reviewed to ensure compliance with Caltech policies and legal requirements prior to offering the individual a visiting appointment.

Applications from Visiting Scholars are subject to I-129 Export Compliance Review.

To sponsor a visitor, please review the visitor types and Visitor Access Request (VAR) process as well as any process required for visiting students. Know that the review process may take 2-3 weeks. Minor volunteers take 4-6 weeks to ensure compliance with mandated reporter requirements and compliance checks.

All visitors are expected to abide by Institute policies and regulations that govern their actions, including but not limited to those of prohibited against discrimination and harassment, ethical behavior, confidentiality, financial responsibility safety, and substance use.

Caltech is committed to fostering an academic environment where faculty, students, and staff are encouraged and supported in collaborating with colleagues from around the world.

The General International Travel webpage provides guidance to researchers traveling to foreign destinations, as well as information about exporting items including hand-carried items. You may send a direct email to [email protected] for questions.

There are special considerations for individuals traveling to Countries of Concern (currently Iran, PRC (including Hong Kong and Macau), North Korea, and Russia) or Sanctioned and Embargoed Countries. Please review this Specific International Travel webpage that includes a checklist for traveling to a Country of Concern.

International Scholars should also review the Travel Advice webpage prior to travel.

Some federal awards require reporting all foreign travel to the sponsor while others may require only reporting of foreign travel to countries of concern. Please review your award summary to ensure you don't have any obligations.

If your travel is paid for or reimbursed by an outside entity and you are Senior/Key Personnel involved in federally funded research, it is necessary to report this travel in the Disclosure of Financial Interests and Commitments.

Disclosure is required when the aggregate value of sponsored or reimbursed travel exceeds an estimated $5,000 for an entity in the previous 12 months. The disclosure of each trip should be submitted as it occurs regardless of the estimated value. (i.e. submit all trips from the last 30 days so as to not need to track value). The aggregate value includes:

• Travel for which the individual is reimbursed by an outside entity
• Travel that is paid for on the individual's behalf by an outside entity
• Any registration fees, accommodations, transportation costs, etc.

The federal government may have restrictions on procurments from countries of concern or entities from countries of concern. Procurement Services has a website describing these restricted and prohibited purchases.

If you are exporting or importing items as part of your research, please visit the Export Compliance Office for requirements in a particular country or licensing requirements for specific activities and the Environment Health and Safety Office or Research Compliance for shipping, labeling, and receiving biological, hazardous, or radioactive materials.

Please contact the OTTCP Material Transfer Agreement team at [email protected] for assistance with MTAs, which may be required to provide materials to, or receive materials from, your collaborators.

Be aware of sponsor restrictions limiting openness in research:

• Awards requiring receipt of controlled information (e.g., classified information, export controlled, or Controlled Unclassified Information (CUI)) generally cannot be accepted unless an exception is approved. Caltech will not generate CUI, Export Controlled or Classified Information, as this is inconsistent with our Openness in Research Policy.
• Awards that include terms requiring approval or excessive delays in publications or are inconsistent with the Fundamental Research Exclusion (15 CFR § 734.8), cannot be accepted unless an exception is approved.
• Awards that require approval for the participation of foreign nationals in the project, may delay the start of a project while the Office of Sponsored Research (OSR) negotiates acceptable terms.

Increasingly, Federal Agencies are requiring a Risk Review and Risk Mitigation Plan from Caltech for certain "Covered Personnel" who are Senior or Key Personnel. A short presentation/slide deck is provided here: Risk Mitigation Powerpoint

General Guidance is provided here.

No Specific NSPM/Research Security Requirements have been implemented yet.

HOWEVER:

• Safeguarding International Science: Research Security Framework from NIST Published in August 2023, seems to be the emerging standard in academia
• Increasing DoD (DoW) Cybersecurity Requirements (CMMC Phase II was Suspended on 7/13/26); however, CMMC Phase I is active as of November 10, 2025)
• More to come...

CALTECH MEMOS

Memo from the Vice Provost - Request for NIH investigator foreign agreements (November 3, 2021)

Memo from the Vice Provost - Travel Advisory for International Scholars (December 11, 2020)

Memo from the President and Provost on the Importance of Disclosure (November 4, 2020)

Memo from the President and Provost on Our International Community of Scholars (July 11, 2019)

Memo from the Vice Provost on Controlled Unclassified Information (November 9, 2018)

EXTERNALREPORTS

• NSTC issues New Common Forms (November 2023)
• DOD issues internal guidance to its funding components for Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education (June 2023)
• Request for Information; NSPM 33 Research Security Programs Standard Requirement (March 2023)
• CHIPS + Science Bill - COGR update of key issues for research institutions (September 2022)
• NSTC Research Security Subcommittee NSPM-33 Implementation Guidance Disclosure Requirements & Standardization (8/31/2022)
• COGR Summary of NSTC Guidance for Implementing National Security Presidential Memorandum 33 Disclosure Requirements V 2.0 (1/11/2022)
• Multi Association Letter to OSTP on NSPM-33 Implementation (9/30/2021)
• COGR Federal Focus on Inappropriate Foreign Influence on Research: Practical Considerations in Developing an Institutional Response (8/18/2021)
• NIH issues report of its findings on foreign influence cases from 2016 to 2021 (7/30/2021)
• NSTC JCORE Report Recommended Practices for Strengthening the Security and Integrity Of America's Science and Technology Research Enterprise (1/19/21)
• NSPM-33 (1/14/2021)
• GAO Report: Federal Research: Agencies Need to Enhance Policies to Address Foreign Influence (12/17/2020)
• MITRE Report on Improper Influence in Federally Funded Fundamental Research (12/2020)
• Science and Security Resource Document (AAU, Updated 12/2020)
• NSF JASON Report "Protecting Research and Facilitating Collaboration" (12/11/19)
• Threats to the U.S. Research Enterprise: China's Talent Recruitment Plans (U.S. Senate, Permanent Subcommittee on Investigations) (11/18/2019)
• Letter to the United States Research Community from White House OSTP Director Dr. Kelvin Droegemeier (9/16/19)
• NOT-OD-19-114 Reminders of NIH Policies on Other Support and on Policies Related to Financial Conflicts of Interest and Foreign Components (7/10/19)
• H.R. 3038 Securing American Science and Technology Act 2019 (5/30/19)
• Actions Taken by Universities to Address Science and Security Concerns (AAU & APLU) (4/22/19)
• Bridging Science and Security (AAAS) (2/21/2012)