Auburn University supports open, ethical, and secure international research collaborations that advance discovery, education, and public impact. Global partnerships are essential to addressing complex challenges and enriching the university’s teaching, research, and outreach mission. At the same time, Auburn University is committed to ensuring that all international engagements comply with U.S. laws and regulations, sponsor requirements, and university policies.
Federal agencies have increased expectations for transparency and accountability in international research. Failure to meet disclosure and research security requirements may result in delays or denial of proposals and awards, termination of active funding, or institutional and sponsor-imposed penalties. In rare cases, noncompliance may lead to civil or criminal consequences. Early disclosure and proactive engagement with university offices are essential to protecting both researchers and the institution.
This page provides key guidance and resources for faculty, staff, and research administrators engaged in or considering international collaborations.
An international collaboration includes any research, scholarly, educational, or technical activity involving a foreign institution, government, company, nonprofit, researcher, or activity conducted outside the United States.
Examples may include:
- Joint research or co-authorship with a foreign collaborator
- Research activities conducted outside the United States
- Exchange or sharing of data, materials, software, equipment, technical information, or samples
- Participation in international consortia, networks, centers, or talent recruitment programs
- Hosting or sending visiting scholars, students, observers, research staff, or visiting scientists
- Foreign gifts, contracts, sponsored research, subawards, consultants, contractors, or vendors
- Holding an appointment, affiliation, lab, or funded role at a foreign institution
- Unfunded or informal research relationships
- International travel related to research
NOTE: Both formal and informal collaborations can carry compliance, disclosure, and security obligations.
Researcher Responsibilities
Faculty, investigators, and research personnel engaged in international collaborations are responsible for ensuring that their activities are properly disclosed, reviewed, and conducted in accordance with institutional, sponsor, and federal requirements.
Researchers should review the responsibilities below before initiating or participating in international research, scholarly, educational, or technical activities.
Researchers must fully and accurately disclose foreign affiliations, appointments, activities, and support, whether funded or unfunded, in accordance with the OSVPRED Procedural Guidance: Disclosure Framework Pursuant to NSPM-33 and applicable sponsor requirements.
Researchers must:
- Disclose all foreign affiliations, appointments, activities, and support, including funded, unfunded, in-kind, or non-monetary support.
- Report all resources made available in support of their work, including lab space, personnel, equipment, materials, data access, or other research support, regardless of whether the resources are provided through AU.
- Ensure consistency across proposal documents, including biosketches, current and pending/other support, and conflict-of-interest disclosures.
- Understand and comply with agency-specific rules regarding foreign components, prior approvals, and participation restrictions, including requirements from federal sponsors such as NIH, NSF, NASA, DOE, DoD, and USDA.
- Disclose foreign components, foreign affiliations, international activities, and other sponsor-required information.
- Obtain sponsor approval before engaging in activities that require advance review or authorization.
- Avoid prohibited relationships and activities, including participation in Malign Foreign Talent Recruitment Programs.
- Complete any sponsor-required training, such as Responsible Conduct of Research and Research Security Training. Training is available through the CITI Program.
- Ensure appropriate agreements are in place before sharing data, materials, software, equipment, confidential information, or technical information. Examples may include MOUs, subawards, material transfer agreements, and data transfer agreements.
- Protect intellectual property, publication rights, student interests, and confidential or sensitive information.
- Promptly disclose inventions or intellectual property arising from international collaborations.
- Protect sensitive data, research systems, and institutional accounts when collaborating internationally.
- Report suspected cybersecurity incidents, compromised accounts, or unauthorized data access.
- Comply with U.S. export control laws and economic sanctions when sharing technology, data, software, equipment, technical information, or materials across borders.
- Exercise additional caution for collaborations involving countries subject to heightened federal scrutiny, including China, Russia, Iran, and North Korea.
- Understand that these collaborations are not necessarily prohibited, but may require enhanced disclosure, due diligence, prior review, and risk mitigation.
- Consult the Research Security Compliance Office before engaging with restricted institutions, restricted individuals, or activities involving sanctioned countries or entities.
Some foreign universities, companies, and research institutions may be subject to U.S. government restrictions, including:
- Office of Foreign Assets Control (OFAC) Sanctions List
- Bureau of Industry and Security (BIS) Entity and Unverified Lists
- DoD Section 1286 List
- NDAA Section 1260H List
Restrictions may affect activities such as:
- Sharing data, software, technology, or technical information
- Exporting or transferring equipment
- Hosting visiting scholars, students, or researchers
- Entering into agreements or collaborations
- Receiving or using federal funding
At Auburn, we promote a risk-aware approach to international collaborations. Before getting started, review the following questions to help identify potential compliance and regulatory considerations:
- Have all foreign roles, resources, and affiliations been disclosed?
- Do I know everyone who will be participating in the collaboration?
- Does the work involve restrictions on publication or participation?
- Will controlled data, technology, or equipment be shared?
- Are export controls or sanctions implicated?
- What funding sources will be used for this collaboration?
- Are appropriate agreements in place?
- Could the collaboration affect future federal funding eligibility?
Frequently Asked Questions
Disclosures should be made through Auburn University’s Conflict of Interest program in Endeavor.
Yes, but these collaborations may require additional review, disclosure, and risk mitigation.
The term "foreign country of concern" means the People's Republic of China, the Democratic People's Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country determined to be a country of concern by the Secretary of State.
As early as possible, especially when planning proposals, agreements, or disclosures.
|
Situation |
Contact |
|
Proposal includes foreign components or collaborators |
|
|
Disclosure of foreign affiliations or other support |
|
|
International agreements (MOUs, subcontracts) |
|
|
Data use, material transfer, or licensing agreements |
|
|
Export controls, sanctions, restricted party screening |
|
|
Any compromised accounts or other IT threats |
NOTE: These contacts are in addition to the requirements of the Office of International Programs International Agreement Approval Process.
Yes, undisclosed or noncompliant activities can jeopardize current or future funding.
External
NSF Secure Center Research Security Reference Library
NSF Secure Center Risk Matrix Reference Guide
Internal
Auburn University Principal Investigator Handbook
Financial Conflict of Interest Policy for Research and Related Activities
International Travel Warning Policy
Policy on Research Security Program Compliance
Policy on Foreign Recruitment Talent Programs
SVPRED Procedural Guidance: Disclosure Framework Pursuant to NSPM-33
Need Help?
International collaboration is a strength of Auburn University. Our goal is to help you collaborate successfully, securely, and compliantly.
If you have questions or are planning an international activity, please contact the Office of Research Security Compliance (aurso@auburn.edu).
This page is intended as guidance and does not replace sponsor requirements or applicable laws and regulations.