Published: May 6, 2024

The University of Colorado Boulder is committed to open scientific research, the intellectual exchange of ideas, and the international academic research collaborations and engagement that facilitate them. 

CU Boulder is also committed to ensuring research security, and requires all employees (including faculty, postdocs and staff) and students with responsibility for the purpose, design, conduct or reporting of research to fully disclose information to identify potential conflicts of interest and conflicts of commitment. To that end, the university is obligated to monitor and regulate participation in certain Foreign Talent Recruitment Programs. 

A Malign Foreign Talent Recruitment Program (MFTRP) is an effort by a foreign government to recruit science and technology professionals or students with the intent to acquire resources to further their military and economic goals. The Federal government has determined that some of these programs pose a threat to national and economic security, and the CHIPS and Science Act (H.R.4346 Sections 10631-10632) has prohibited participation in them for recipients of federal grants. 

In response to the CHIPS and Science Act, CU Boulder has adopted a policy that prohibits all employees (including faculty, postdocs and staff) from participating in a MFTRP. Participation includes, but is not limited to:

  1. Affiliation with or membership in an MFTRP, including a contractual or other binding agreement between an individual and a MFTRP;
  2. An individual reporting participation in an MFTRP in a research proposal, curriculum vitae, or resume; or
  3. An individual's identification in a publication listing the individual and an MFTRP.

The new policy has been incorporated as an amendment to the Academic and Academic and Researcher Conflicts of Interest and Commitment Policy and Standards.

The policy requires employees (including faculty, postdocs and staff) and students to seek guidance from the Office of Research Integrity ( prior to agreeing to participate in any program or activity or to accepting an appointment to any position sponsored by a foreign country or entity regardless of whether they believe it to be a MFTRP. 

All requests for guidance and disclosures will be reviewed by the Office of Research Integrity, which will determine whether the participation or appointment is permissible. When it is impermissible, the individual is required to immediately decline or cease participation, as applicable. If the individual does not agree with the determination of impermissibility, they may submit their concerns in writing to the Vice Chancellor for Research and Innovation for further consideration. 

Learn more about how to identify potential malign foreign talent recruitment programs.