The rCOI Disclosure Form has been updated to include a new question (Question 4) regarding participation in foreign talent recruitment programs. This update is necessary to comply with federal requirements, particularly those aimed at identifying and preventing involvement in malign foreign talent recruitment programs.
If you are currently or have previously been involved in any foreign talent recruitment program, it must now be disclosed as part of your rCOI disclosure submission.
Please note that if your disclosure includes significant financial interest(s), you will need to update it to answer the new question about foreign talent recruitment programs. Failure to do so may delay the acceptance of any new awards or award modifications, as they will be held up at ORS until the disclosure is updated. We recommend all investigators and key persons involved in extramurally-funded activities to update your disclosure as soon as possible, rather than waiting until you have an award pending acceptance.
What Are Malign Foreign Talent Recruitment Programs?
Malign foreign talent recruitment programs are efforts by foreign governments to recruit individuals to participate in activities that may undermine U.S. research integrity, export controls, or national security. These programs may involve:
- Unauthorized transfer of intellectual property, materials, or other nonpublic information.
- Establishing a lab, company, or accepting a faculty position or appointment in the foreign country.
- Terms that conflict with U.S. laws, university policies, or ethical research practices.
- Requirements to omit acknowledgment of UH or the federal agency sponsoring the research.
Participation in these programs can compromise research integrity and lead to serious consequences, such as violations of federal law, loss of federal funding, or damage to personal and institutional reputations.
Learn more about malign foreign talent recruitment programs on our Malign Foreign Talent Recruitment Program page.
If you have any questions, please feel free to contact the UH Conflicts of Interest Office at coi@hawaii.edu.