International Collaborations and Disclosure Requirements

USC is engaged in far-reaching, global research and recognizes the importance of these international collaborations. To protect the security of the research enterprise, federal sponsors are placing increased emphasis on the disclosure of foreign affiliations, relationships and sources of support, whether they are funded or in-kind support. Conflicts of interest and commitment, especially with foreign entities, are a key focus of the recent National Security Presidential Memorandum 33 (NSPM 33) and the CHIPS and Science Act, which are designed to safeguard United States research and researchers. The resources on this page aim to assist faculty in ensuring relationships with foreign entities comply with federal disclosure requirements.

Background Information

“Understanding International Engagement Disclosure Requirements”: Training on TrojanLearn

Quick Guide on Disclosure of Foreign Relationships

Foreign Relationship Reporting Guidance: When and Where to Report

Presentation – International Engagement (Key Considerations)

Memorandum on International Collaborations, Export Controls, and Disclosure Requirements

FAQs on Faculty Foreign Research Relationships

Sponsor Guidance

New Federal Common Disclosure Forms for Biographical Sketch and Current and Pending (Other) Support – STARTING MAY 25, 2025

National Institutes of Health (NIH)

**NEW** Reminder – Definition of Foreign Components (May 2026) – expanded the previous definition on foreign components

**NEW** Research Security Training Requirements for NIH (December 2025) – Required for applications submitted for due dates on or after May 25, 2026

**NEW** New Application Structure for NIH-Funded International Collaborations (September 2025) – Effective for due dates on or after January 25, 2026, competing applications requesting funding for foreign components must use NIH’s new international collaboration award structure

**NEW** Updated NIH Policy on Foreign Subawards (May 2025) – Applies to applications submitted before May 1, 2025, and active projects on or before May 1, 2025

NIH Processes and Decision Matrix for Reviewing Foreign Activities (August 2024)

NIH Requirements for Disclosure of Other Support, Foreign Components and Conflicts of Interest (August 2023)

NIH One-Pager On Disclosure Requirements Effective 1/25/2022 – USC Guidance

NIH Update to USC Faculty and Staff Memo (October 2021) – USC Guidance

NIH Changes Explained Slide Deck (June 2021) – USC Guidance

Foreign Interference in National Institutes of Health Funding and Grant Making Processes: A Summary of Findings From 2016 to 2021 (July 2021)

National Science Foundation (NSF)

**NEW** Prohibition on Collaborations with Restricted Entities – Beginning in FY 2027, senior/key personnel on NSF-funded projects will be prohibited from collaborating with entities on U.S. restricted parties lists. Institutions and senior/key personnel will be required to certify compliance with these restrictions during proposal submission.

**NEW** NSF SECURE Center

Important Notice No. 149: Updates to NSF Research Security Policies (Updated November 2025) – Effective December 2, 2025, including research security training certification, required supporting documentation for foreign appointments/employment/talent program participation, MFTRP certifications, Confucius Institute restrictions, and updated Foreign Financial Disclosure Report requirements

NSF Biographical Sketch and Current and Pending Support Disclosure Information (summary table updated January 2023)

NSF-approved biographical sketch and current and pending support formats: NSF biographical sketch and current and pending support

NSF FAQs on Current and Pending Support (Effective June 1, 2020; Updated February 2023)

Dear Colleague Letter Regarding Research Protection (July 2019)

Department of Defense (DoD)

DoD webpage on Academic Research Security, including the DoD risk matrix, policy for risk-based security reviews of fundamental research projects, 1286 entity list, and relevant memos.

**NEW** 2026 DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions

Department of Defense (DoD) 1260H List (UPDATED JUNE 2026): List of names of “Chinese military companies” operating directly or indirectly in the United States.

Memorandum Enlisting University Partnership (October 2019)

Memorandum Regarding Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies (March 2019)

Department of Energy (DoE)

**NEW** DoE Covered Individual Form – DOE now requires covered individuals to complete the Common Forms for Biographical Sketch and Current and Pending (Other) Support in SciENcv, certify no current participation in a Malign Foreign Talent Recruitment Program, and, for R&D proposals, certify completion of research security training.

**NEW** DoE Research Security Training Requirement (October 2024) – Covered individuals must complete research security training within the 12 months before application submission for applicable R&D applications/projects; mandatory as of May 1, 2025.

Department of Energy Current and Pending Support Disclosure Requirements (June 2022)

National Aeronautics and Space Administration (NASA)

**NEW** NASA Research Security Training Requirement (February 2026)

**NEW** NASA Grant and Cooperative Agreement Manual / Common Disclosure Forms – Effective October 1, 2024, covered individuals must submit NASA’s biographical sketch and current and pending support disclosure forms with applications.

**NEW** NASA Pre-Award and Post-Award Disclosure Requirements – NASA provides a disclosure matrix identifying which activities must be disclosed in the biographical sketch, current and pending support, facilities/equipment/other resources, and project reports.

U.S. Department of Agriculture / National Institute of Food and Agriculture (NIFA)

**NEW** NIFA Application Support Templates – Add NIFA’s current Biographical Sketch and Current & Pending Support templates, including the March 2025 Current & Pending Support template.

**NEW** USDA Research Security Training Requirement (July 2025)