Disclose Foreign Collaborations and Support

International collaborations and support are a growing area of concern and interest for agencies who fund research. 

 Sponsors generally want to know about:

  • Visiting scholars/students, especially when funding is from a foreign institution/government
  • International collaborations in sponsored projects, even when no money is exchanged (in-kind support)
  • Outside appointments: domestic or foreign, paid or unpaid, full/part-time/voluntary (including adjunct, visiting or honorary)
  • Foreign travel
  • Other sources of support though Cornell, an outside entity, or a personal venture.

Note: Check this page frequently due to changing sponsor requirements. 

What do I need to do?

#CategoryDescriptionActions to TakeRelevant Policy/Guidance
1Screen and Monitor VisitorsWorking with foreign collaborators on Cornell University grounds is often vital and productive to the research enterprise. If you are bringing a visitor to campus, whether a fellow scientist, student, or funder, make sure that you have properly vetted them and provide adequate supervision. 

Email academicvisitors@cornell.edu with details. 

 

For sponsors: Disclose in Current, Pending, and Other Support forms as necessary. 

Export Controls in Research and Education 
2Foreign Collaborations in Sponsored ProjectsCollaboration with a foreign entity (including but not limited to subawards, consultants, funded or unfunded collaborations with investigators located at a foreign site, etc.) in a project must be disclosed in funding applications and project reports. Additionally, adding a foreign collaboration and/or component to an existing award may require prior approval from the sponsor. 

For sponsors: Review and follow sponsor requirements listed in funding opportunities and award documents. 

Report to Cornell: Use a checkbox to record foreign activities related to the project in RASS. This checkbox will alert Global Operations and/or Export Controls, who will reach out with further guidance. 

Foreign activities may include foreign collaborators, foreign consultants, foreign components, publications with foreign collaborators, procurements, subcontracts to foreign entities, overseas shipments, or travel to foreign countries. 
3Disclosing All Sources of Support

All current and pending support of your research endeavors, whether this effort is though Cornell, through an outside entity, or a personal venture, must be disclosed to external research sponsors as required by their guidelines and regulations. This includes both foreign and domestic sources of support and both funded and in-kind sources of support.

Report to Cornell: Add to Conflicts of Interest (COI) in RASS. 
 
For sponsors: Disclose to sponsors on Current, Pending, and Other Support, and Biosketch forms as necessary.

 

Researchers cannot rely solely on research administrators to complete their current and pending support reports. Research administrators will not have access to all information required to be disclosed to sponsors through Cornell systems. 
4Disclosing All Appointments and Affiliations

All academic professional, or institutional appointments held by researchers must be disclosed. This includes those that are domestic or foreign, paid or unpaid, or full/part-time/voluntary (including adjunct, visiting or honorary).  

Report to Cornell: Add to Conflicts of Interest (COI) in RASS. 
 
For sponsors: Disclose to sponsors on Biosketch forms and Current, Pending, and Other Support forms per sponsor requirements. 

RASS COI Guide
5Consulting Activity

All time spent working for or consulting with any entities or institutions, foreign or domestic, must be reported to Cornell, regardless of whether such activity is conducted in your professional or personal capacity, and whether such effort is paid or unpaid.  

Report to Cornell: Add to Conflicts of Interest (COI) in RASS. 
 
For sponsors: Disclose to sponsors on Biosketch forms and Current, Pending, and Other Support forms per sponsor requirements.

Disclose to sponsors on Biosketch forms and Current, Pending, and Other Support forms per sponsor requirements.
6Foreign Travel

Observe the appropriate security precautions when traveling. 

Register your travel in the Cornell travel registry and follow the international travel guidelines from Cornell’s IT Security Office

Federal regulations require researchers to disclose:

  • any foreign or domestic travel that is related to the researcher’s institutional responsibilities 
  • and is paid for or reimbursed by non-Cornell entities.

Report to Cornell: Add to Conflicts of Interest (COI) in RASS. 
 
Before you travel, disclose the trip in the Cornell travel registry

Travel and International Activities and Export Controls and International Travel
7Negotiating Unfunded Research Collaborations with Foreign Entities

All unfunded collaboration agreements and non-sponsored revenue-generating agreements must be initiated by your unit's contract administrator and include standard language to protect academic freedom, intellectual property, and non-discrimination.  

Exploring an Academic Collaboration
8Malign Foreign Talent ProgramsParticipation in a Malign Foreign Talent Recruitment Program (MFTRP) by any Cornell employee or researcher is strictly prohibited. 
 

Report to Cornell: All Cornell faculty and researchers must complete an annual MFTRP certification in Conflicts of Interest (COI) in RASS. 


Senior/key personnel on federally funded awards may have separate certification requirements. 

Malign Foreign Talent Government Recruitment Programs

Who can answer my questions?

CategoryIncludingContact

Bringing international researchers and faculty to the U.S. 

Advice and assistance 

International Services in the Office of Global Learning 

Conflict of Interest (COI) disclosures 

 Financial and Conflict of Commitment (COC) 

Export controls

 Shipping, imports 

Restricted party screening 

New hire screening, visitor screening 

Disclosures to external sponsors 

International collaborations and funding 

Find my GCO to contact your assigned Grant & Contract Officer 

Guidance regarding work with China 

  

Other international contracts 

Formalization of collaborations with foreign institutions 

Malign Foreign Talent ProgramsAdvice and assistanceContact researchsecurity@cornell.edu

Where can I find more information?