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Office of Research and Innovation

Research Compliance

High Risk Global Engagements and High Risk International Collaborations In Research

Welcome to the High Risk Global Engagements and High Risk International Collaborations in research website.

This site has the required research-related forms and links to be completed by individuals.

Take a look at our Frequently Asked Questions About International Collaborations and Other International Activities Involving Countries of Concern Definitions: Please note the following definitions apply regarding the below FAQs:

Countries of Concern: Defined by Texas A&M System Research Security Office (RSO) quarterly, and are currently China, Russia, Iran, and North Korea.

RC: Texas A&M University-Kingsville Office of Research Compliance

EC: Texas A&M University-Kingsville Office of University Export Controls

ECO: Export Control Officer/Empowered Official

Texas A&M University-Kingsville: TAMUK

TAMUK encourages its faculty and staff to establish global engagements in the pursuit of mutually beneficial fundamental scientific inquiries, and cultural, or educational opportunities. These activities strengthen the academic and research programs and are fundamental to the university’s mission.

Any questions regarding the High Risk Global Engagements and High Risk International Collaborations in research should be directed to the Office of Research Compliance as soon as possible.

  • International Collaboration Request Form
    • This form allows Principal Investigators to notify their supervisors of proposed international collaborations.  Since is it in DocuSign and will require the upload of Restricted Party Screenings and any other relevant information related to the proposed collaboration, please have these files ready before filling in the form.  
    • This will route to the PI's supervisors, and if they acknowledge the collaboration may proceed for official review and execution, it will be sent to the appropriate parties to complete TAMUK and TAMU System processes for agreements. 

  1. How does one define international collaborations?
    1. Any of the following relationships with entities or individuals based outside the United States: student and faculty exchanges; education abroad programs; placements abroad; unfunded research relationships; technical assistance; unfunded professional development, training, and services; unfunded outside appointments, honorary positions, peer review, or distinguished positions; unfunded outside support including but not limited to lab space or other resources, provided either physically or virtually; activities with international entities traditionally compensated by a payment, honorarium, or paid travel expenses. Such collaborations require appropriate disclosures such as Financial Conflict of Interest, Conflict of Commitment, and/or Faculty Consulting and/or External Employment. 
    2. Please see: 
      1. TAMUK Rule 15.01.03.K1 Financial Conflicts of Interest in Sponsored Research, 
      2. System Regulation 15.01.03 Financial Conflicts of Interest in Sponsored Research, 
      3. TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment
      4. System Regulations 31.05.01 Faculty Consulting and/or External Professional Employment and 31.05.02 External Employment.  
      5. See FAQ 6 for additional requirements pursuant to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations and TAMUK Rule 15.05.04.K1
  2. Why are there rules and requirements for High Risk global engagements and other international collaborations?
    1. TAMUK is committed to protecting the integrity of research and educational programs, including the interests of all involved in contractual relationships and international collaborations.
    2. Many funding agencies require formal disclosures by individual researchers and/or institutions concerning international engagements, collaborations, and funding sources to ensure compliance, and in many cases have now moved the responsibility for the accuracy of these disclosures to the institution.
  3. Who do all of these rules and regulations apply to?
    1. System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations and TAMUK Rule 15.05.04.K1
      1. All System member employees
    2. System Regulation 15.01.03 Financial Conflicts of Interest in Sponsored Research and TAMUK Rule 15.01.03.K1 Financial Conflicts of Interest in Sponsored Research
      1. Any employee who is responsible for the design, conduct, or reporting of research or research activities on externally sponsored research
    3. TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment
      1. Full time faculty members with a 9 month or greater appointment
      2. Full or part time faculty members holding 50 percent or greater appointments
      3. Part-time faculty members holding less than 50 percent appointments only if the activity reasonably appears to create a conflict of commitment
      4. Full time professional and administrative employees
      5. Part time professional and administrative employees only if the activity reasonably appears to create a conflict of commitment
    4. System Regulations 31.05.01 Faculty Consulting and/or External Professional Employment and TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment
      1. Full-time faculty members for activities directly related to their academic and professional discipline
      2. Includes uncompensated scholarly or research activities involving a country of concern
    5. System Regulation 31.05.02 External Employment
      1. All employees other than faculty covered by System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment
      2. Includes external employment by faculty members that is not directly related to their professional discipline
      3. Includes uncompensated scholarly or research activities involving a country of concern
    6. System Regulation 12.99.01 Faculty Development Leave
      1. Those faculty members who meet the eligibility requirements as listed in the FDL regulation
  4. What is impacted by the System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations and TAMUK Rule 15.05.04.K1?
    1. High Risk Global Engagement: contracts with one or more Foreign Persons based outside the United States in a Country of Concern.
    2. High Risk International Collaboration: any of the following relationships with Foreign Persons based outside the United States in a Country of Concern: student and faculty exchanges; placements abroad; unfunded research relationships; technical assistance; unfunded professional development, training, and services; unfunded outside appointments, honorary positions, peer review, or distinguished positions; unfunded outside support including but not limited to lab space or other resources, provided either physically or virtually; activities with Foreign Persons traditionally compensated by a payment, honorarium, or paid travel expenses.
    3. The regulation covers all academic and research (funded and unfunded) agreements and collaborations between the university and an entity or person located in a country of concern.
    4. This includes all agreements and sub-agreements between the university and an entity or person located in a country of concern (includes but is not limited to contracts, MOUs, MOAs, student exchanges, non-disclosure agreements, data use/transfer agreements, and dual research agreements).
    5. Please note that certain international collaborations fall under additional System regulations as follows:
      1. High Risk international collaborations require review and approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations and 15.05.04.K1.
      2. TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment
        1. Certain types of scholarly or research expertise to foreign entities located in a country of concern without compensation constitutes “faculty consulting and/or external professional employment” for purposes of this regulation and require prior approval. These types include, but are not limited to, participation in scholarly or scientific research projects or publications required to be disclosed to any agency of the US government, as well as communication of any information subject to export control, publication restriction, or confidentiality agreement.
        2. Please see the below FAQs for answers to specific questions pertaining to the above definition.
      3. System Regulation 31.05.02 External Employment,
        1. Certain types of scholarly or research expertise to foreign entities located in a country of concern without compensation constitutes “external employment” for purposes of this regulation, and requires prior approval. These types include, but are not limited to, participation in scholarly or scientific research projects or publications required to be disclosed to any agency of the US government, as well as communication of any information subject to export control, publication restriction, or confidentiality agreement.
        2. Please see the below FAQs for answers to specific questions pertaining to the above definition.
    6. Only authorized officials are able to sign agreements on behalf of the University pursuant to TAMUK Rule 25.07.99.K1.   Academic agreements are approved by the Vice President for Academic Affairs, or designee. Research Agreements are approved by the Associate Vice President for Research or designee.
  5. What are the countries of concern as identified by RSO and how are they determined?
    1. Presently there are four countries of concern as identified by RSO as it pertains to this regulation. These countries were selected because they have demonstrated organized efforts to illicitly acquire intellectual property from other nations, are involved with industrial and/or cyber espionage, and demonstrate efforts to damage US economic and national security. 
    2. Country or countries designated by System Research Security Office as “of concern” for purposes of System Regulation 15.05.04 based on US government annual reports to Congress and guidance from federal partners including the Defense Counterintelligence and Security Agency.  Countries of concern are reviewed quarterly.
  6. What is deemed high-risk collaborations?
    1. Any of the following relationships with Foreign Persons based outside the United States in a Country of Concern: student and faculty exchanges; placements abroad; unfunded research relationships; technical assistance; unfunded professional development, training, and services; unfunded outside appointments, honorary positions, peer review, or distinguished positions; unfunded outside support including but not limited to lab space or other resources, provided either physically or virtually; activities with Foreign Persons traditionally compensated by a payment, honorarium, or paid travel expenses.
  7. Can we invite visiting scientists from countries of concern to TAMUK?
    1. Visiting scientists from countries of concern (with the exception of Russia) is encouraged, but visiting is dependent on their affiliation, and the nature of the work, collaboration, or purpose of the visit. The appropriate documentation that addresses the home institution, purpose of visit, duration of visit, and funding source is required to be submitted for review and approval.   
    2. Visiting Scholars affiliated with an entity on the list will be denied.
    3. Russia: No collaborations are acceptable at this time. 
  8. Can we invite students from countries of concern to TAMUK?
    1. Students will be allowed. Student activities related to the research may be subject to other reviews, such as export control compliance.
  9. Can we hire faculty/researchers/students from countries of concern?
    1. Yes, if the individual meets all applicable A&M System hiring requirements related to work authorization, background checks, degree verification, etc. Reference System Regulation 33.99.09 Employment of Foreign Nationals.
  10. Can TAMUK faculty continue collaborations with former students in a country of concern?  What if the research was almost complete prior to the student leaving for an institution in a country of concern – can the research be completed and published?
    1. It depends on the specific institution within the country of concern and the nature of the collaboration. The proposed collaboration should be submitted to the ECO for review and approval pursuant to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations prior to continuing the collaboration. 
    2. Russia: No collaborations are acceptable at this time.
  11. Can researchers publish and co-author papers with colleagues in countries of concern? 
    1. The proposed collaboration should be submitted to the ECO for review and prior approval pursuant to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations prior to continuing the collaboration.
    2. Collaboration with colleagues affiliated with an entity on the list will be denied.
    3. Russia:  No collaborations are acceptable at this time.
    4. If the collaboration is not part of your normal duties or if you are receiving compensation, the activity must be submitted for review and approval under TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment.   The activity will also be subject to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations if it involves an entity/individual located in a country of concern.
  12. Can faculty have regular Zoom meetings with colleagues in countries of concern to discuss collaborations?
    1. Collaborations with any colleague in a country of concern depend on the colleague; their affiliation; and the nature of the work/collaboration. Zoom meetings to discuss collaborations (funded or unfunded) can continue as long as the collaboration has been disclosed to the University and any Federal sponsors where applicable and has received approval from the ECO pursuant to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
    2. Russia: No collaborations are acceptable at this time.
  13. Can we still have colleagues on our graduate faculty as members on graduate student committees from countries of concern?
    1. Representation will depend on the individual and their affiliations and must be submitted to ECO for approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations. 
    2. Representation from entities on the list will not be approved.
    3. Russia: No collaborations are acceptable at this time.
  14. Can we host visiting scholars from countries of concern? Does it matter if they are funded by the home institution of the scholar, funded by the home country of the scholar, funded privately, or funded by TAMUK? 
    1. It depends, each visitor request will be reviewed on a case-by-case basis. The purpose, source of support, and benefit to the University will be factors in the review. 
    2. Visiting Scholars affiliated with an entity on the list will be denied.
    3. Currently for Russia, no.
  15. Can we co-author peer-reviewed journal articles and book chapters with known scientists from these countries of concern?
    1. The proposed collaboration should be submitted to the ECO for review and prior approval pursuant to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations prior to continuing the collaboration.
    2. Collaboration with colleagues affiliated with an entity on the list will be denied.
    3. Russia:  No collaborations are acceptable at this time.
    4. If the collaboration is not part of your normal duties or if you are receiving compensation, the activity must be submitted for review and approval under TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment.
  16. Can we review journal manuscripts authored by known scientists from countries of concern? 
    1. If the journal is located in a country of concern, it must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  17. Can we participate in collaborative research in grants funded by countries of concern (with proper disclosure to TAMUK)? 
    1. Any collaboration from a country of concern must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
    2. Collaboration with colleagues affiliated with an entity on the list will be denied.
    3. Russia: No collaborations are acceptable at this time.
    4. If the collaboration is not part of your normal duties or if you are receiving compensation, the activity must be submitted for review and approval under TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment.
  18. Can we present papers and presentations at international conferences hosted in countries of concern? 
    1. No, if it is hosted by entities on the list.
    2. For other entities in countries of concern, reviews are conducted as part of the approval requirement.
    3. If research collaborations will occur as part of the presentation and the collaborator is affiliated with an entity from a country of concern, it must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
    4. Currently for Russia, no. 
  19. What if the international conference includes a panel/session with a scholar from Russia or an entity of concern?  Do I need to withdraw my presentation? 
    1. No, but if the conference is located in a country of concern and research collaboration will occur as part of the conference, and the collaborator is affiliated with an entity from a country of concern, it must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  20. Many researchers travel to conferences with no clear sense of who will be there until they arrive. Many of these conferences could have over a thousand attendees.
    1. If the conference is located in a country of concern and a research collaboration will occur as part of the conference and the collaborator is affiliated with an entity from a country of concern, it must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  21. Can we teach courses/short courses/workshops hosted by institutions within countries of concern?
    1. The proposed collaboration from a country of concern must be submitted to ECO for review and prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
    2. Activities affiliated with an entity on the list will be denied
    3. Currently for Russia, no. 
    4. If the activity is not part of your normal duties or if you are receiving compensation, the activity must be submitted for review and approval under TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment and 31.05.02 External Employment.
  22. Can we conduct faculty-led education abroad courses/field trips to countries of concern?
    1. All faculty-led education abroad trips must have their travel pre-approved by the University through Concur.  As part of the Concur process, the trip will be reviewed by ECO, and will include review and prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
    2. Activities affiliated with an entity on the list will be denied
    3. Currently for Russia, no.
    4. If the activity is not part of your normal duties or if you are receiving compensation, the activity must be submitted for review and approval under TAMUK Rule 31.05.01.K1 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment and will require approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  23. Can I serve as an advisor/mentor/graduate committee to a graduate student enrolled at an entity on the list?
    1. Prior to serving as an advisor/mentor/graduate committee to a graduate student located in a country of concern, it must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  24. Can I serve on a program committee for [foreign conference]; the conference is either virtual or in a foreign country.  Do I need to submit through the external employment process for this activity?
    1. If it is hosted by entities on the list, it is not allowed.
    2. For other entities in a country of concern, approval is not required under System Regulations 31.05.01 Faculty Consulting and/or External Professional Employment and/or System Regulation 31.05.02 External Employment; however, reviews will be conducted as part of the approval requirement and required under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations. 
    3. Virtual conference requests for entities located in a country of concern should be sent to the ECO for review and prior approval pursuant to System Regulation 15.04.04 High Risk Global Engagements and High Risk International Collaborations, and TAMUK Rule 15.05.04.K1.
  25. I am a co-author of a paper that has several co-authors from foreign entities.   Does this require me to submit through the external employment process?  What if I don’t know all of the co-authors or their affiliations?
    1. Any known co-author that you are directly collaborating with that is located in a country of concern must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
    2. If it involves entities on the list, it is not allowed.
    3. For other entities in countries of concern, prior approval under System Regulations 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment is required if you are being paid by a foreign entity in a country of concern.   All co-authors may still be required to be disclosed to federal sponsors and/or through the Huron disclosure process.
  26. Is there a situation where the receipt of an honorarium would require external employment approval? 
    1. If it involves entities on the list, it is not allowed.
    2. For other entities in countries of concern, if the honorarium is from a foreign institution in a country of concern or if the work requires more than a minimal amount of the employee’s time, pre-approval is required under System Regulations 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment.
    3. It may still be required to be disclosed to federal sponsors and/or through the Huron disclosure process.
    4. For purposes of this FAQ, an honorarium is defined as a voluntary payment that is given to a person for services for which fees are not legally or traditionally required.  Please note payments to employees or payments to independent contractors are not honoraria (such as where an amount has been agreed upon by the individual providing the service and the individual/entity seeking service), nor are recurring payments to the same individual.
  27. Do I need to submit through the external employment process to present at a conference/workshop (either in person or virtually) in a foreign country? 
    1. Prior approval is required for all foreign travel. 
    2. For conferences/workshops located in a country of concern, any collaborations involving an individual/entity located in a country of concern must be submitted to ECO for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  28. Do I need to submit through the external employment process for a peer review of another university’s department (external review board)?
    1. If it involves entities on the list, it is not allowed.
    2. If you are receiving payment or it is not part of your service mission, it must be submitted for external employment review under System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment.
    3. If it involves entities located in a country of concern, prior approval is required under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  29. Do I need to submit through the external employment process to serve on an international graduate student committee (not a TAMUK student) for a foreign institution?
    1. If it involves entities on the list, it is not allowed.
    2. If you are receiving payment or it is not part of your service mission, it must be submitted for external employment review under System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 
    3. External Employment.
    4. If it involves entities located in a country of concern, prior approval is required under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  30. Do I need to submit through the external employment process to review a non-TAMUK student thesis?
    1. If it involves entities on the list, it is not allowed.
    2. If you are receiving payment or it is not part of your service mission, it must be submitted for external employment review under 31.05.01 Faculty Consulting and/or External Professional Employment and 31.05.02 External Employment.
    3. If it involves entities located in a country of concern, prior approval is required under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
  31. Do I need to submit through the external employment process for receiving an honorarium or payment for serving on a US grants review panel?
    1. No, provided that no more than a nominal amount of the employee’s time is required, and it is within the faculty member’s normal duties and responsibilities.
  32. Do I need to submit through the external employment process for receiving an honorarium or payment for serving on a foreign grants review panel?
    1. Yes, approval is required under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations. If the review panel is located at an institution in a country of concern whether or not compensation is received.
  33. What are researchers required to disclose pertaining to international collaborations?
    1. Financial Conflicts of Interest:  Requirements are outlined in TAMUK Rule 15.01.03.K1 
    2. Financial Conflicts of Interest in Sponsored Research and System Regulation 15.01.03 
    3. Financial Conflicts of Interest in Sponsored Research.   
    4. It should be noted that each sponsor also has their own set of disclosure requirements pertaining to international collaborations.
    5. External Employment: Requirements are outlined in TAMUK Rule 31.05.01.M1 Faculty Consulting and/or External Professional Employment and System Regulations 31.05.01 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.02 External Employment.  Specifically, regarding international collaborations and in addition to compensated outside activity with a foreign entity, the definitions of “faculty consulting and/or external professional employment” and “external employment” also require review and approval for “the provision of certain types of scholarly or research expertise to foreign entities without compensation.” 
    6. Global Engagements: Requirements are outlined in System Regulation 15.04.04 High Risk Global Engagements and High Risk International Collaborations and TAMUK Rule 15.05.04.K1.
  34. I am traveling internationally.  What approvals do I need?
    1. Travel requires prior approval for all foreign travel pertaining to official university business. 
    2. If working remotely in an international location, see also the University Guidelines for International Temporary Work Location (ITWL) Requests.
    3. In addition, all foreign travel to a country of concern is reviewed for export control and research security concerns, and if it involves a High Risk global engagement and/or a High Risk international collaboration subject to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations. 
  35. I serve on a dissertation committee. What approvals do I need?
    1. While serving on a dissertation committee is not typically a reportable activity, you should be mindful that future collaborations as a result of the dissertation may become research and require reporting. You may also need to include the student’s name on your NSF COA table.