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On December 31, 2025, the USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), effective immediately, for all future USDA awards. The new General T&Cs include several research security-related requirements, including institutional certification regarding foreign ownership, control, or influence by a country of concern, institutional malign foreign talent recruitment program certification, institutional research security training certification, and institutional certification of Common Form information.

On December 31, 2025, USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), applied effective immediately to all future USDA awards. The new General T&Cs include several research security-related requirements: institutional certification regarding foreign ownership, control, or influence by a country of concern; institutional malign foreign talent recruitment program (MFTRP) certification; institutional research security training certification; and institutional certification of Common Form information.

Issued July 8, 2025. This memorandum: a. Requires all USDA Mission Areas, Agencies, and Offices to: i. Within 30 days, conduct a comprehensive review of all current USDA awards/subawards with foreign persons/entities and provide justification as to why a US recipient was not selected, ii. Effective immediately, request approval (including justification) prior to issuing an award/subaward to a foreign person/entity. b. Requires applicants (i.e., covered individuals) to: i. Complete the Common Forms for Biographical Sketches and Current and Pending (Other) Support and provide updated information annually, ii. Certify they are not a participant in a malign foreign talent recruitment program (MFTRP) and recertify annually, iii. Certify that they are not contracting with or providing benefit to any foreign person/entity in a country of concern, iv. Certify that they are not party to utilizing forced labor, v. Complete an annual disclosure of contracts associated with participation in programs sponsored by foreign governments/entities, vi. Seek approval from USDA to subaward any portion of a funded arrangement, including university students, post-doctoral fellows, and visiting researchers. c. Requires Employing Entities to: i. Certify to applicants' completion of research security training, ii. Prohibit applicants who either are currently or have in the past 10 years participated in MFTRPs from working on USDA projects, iii. Provide supporting documentation for foreign activities reported as current and pending support, iv. Review any documents required under the memorandum for compliance with USDA award terms and conditions.