Countries of Concern
The CHIPS and Science Act (2022) defined a foreign country of concern as China, Iran, North Korea, and Russia. CHIPS also noted that “entities” located outside of a foreign country of concern but owned, controlled, or subject to the jurisdiction of a country of concern are also subject to restrictions.
This designation, along with other research security actions taken by federal funding agencies, has impacted some researchers more than others. In some cases, research security measures have led to increased concern about international collaboration and international collaborators. At Vanderbilt, there is no room for prejudice, discrimination, or xenophobia. If you feel that research security concerns are being used for discriminatory purposes, you can report this to the Equal Opportunity and Access Office. If you have questions about research security, please reach out to ric@vanderbilt.edu.
Yes. In most cases, you may still conduct research in countries of concern or with researchers in countries of concern. This designation of countries of concern is not being used to ban all research collaboration in these countries. However, there may be sponsor or program specific restrictions for countries under this designation.
For university researchers, the designation of countries of concern is mainly being used to define Malign Foreign Talent Recruitment Programs. The CHIPS and Science Act National Security Guardrails also prohibits recipients of CHIPS funds from supporting semiconductor manufacturing in foreign countries of concern and restricts some research engagements with entities of concern.
Federal funding agencies are using the designation of foreign countries of concern as a basic marker of risk. For example, the Department of Defense has developed a risk matrix which requires the use of mitigation measures for researchers who receive DoD funding and already have funding from a country of concern. This general approach is being utilized by other federal sponsors.
At the most basic level, this means that if you are collaborating with researchers or institutions in countries of concern it could be more closely reviewed by federal sponsors. It is vital that you disclose these collaborations to both Vanderbilt and to federal funding agencies, since even unintentional non-disclosure can have consequences for researchers.
If you are planning an international collaboration with a country of concern and would like more guidance, please reach out to Research Integrity and Compliance for help reviewing your collaboration.
You may also request a Restricted Parties Screening Request from Vanderbilt Export Compliance to ensure your collaborator is not on a denied or blocked parties list maintained by the US government. In the event an individual or entity appears on one of the lists, additional due diligence may be needed before proceeding.
Yes, you may recruit graduate students and postdocs from a country of concern. The designation of country of concern in CHIPS does not restrict the recruitment of international graduate students or postdocs. However, if those students or postdocs are being funded by entities or institutions in or controlled by countries of concern, please review that funding to ensure that it is not part of a Malign Foreign Talent Recruitment Program and report in-kind support to your sponsors.