Mitigation Strategies

A March 2024 report commissioned by NSF and issued by the JASON group. Recommends NSF adopt a dynamic approach for identifying potentially sensitive research topics as they arise and weigh the balance between the protective benefits and the unintended negative consequences of controls on sensitive research. It is suggested that the identification of sensitive projects proposed to NSF occurs most naturally before peer or panel review. Specific mitigation strategies for sensitive research projects should be negotiated and agreed upon by the principal investigator (PI), NSF, and the institution and be proportionate to the assessed risk, relative to the associated costs.

Issued June 29, 2023 by DoD. The document includes: 1. A Policy on Risk-based Security Reviews of Fundamental Research, 2. A Decision Matrix to Inform Fundamental Research Proposal Mitigation (Amended May 5, 2025), 3. A list of foreign institutions identified as engaging in problematic activity (Part 3, Table 1, Amended June 24, 2025), and 4. A list of foreign talent recruitment programs identified as posing a threat to U.S. national security interests (Part 3, Table 2). The Decision Matrix contains four factors for assessing senior/key personnel disclosures: a. Participation in foreign talent recruitment programs, b. Current or prior funding from foreign countries of concern (FCOCs), c. Filing a patent in an FCOC or on behalf of an FCOC-connected entity without disclosure, and d. Associations or affiliations with organizations on U.S. Entity (trade restriction) and other indicated (U.S. restricted) lists.

Issued on November 26, 2024. DOE's RTES office issued a 'framework to minimize, mitigate, and manage risks while maintaining an open, collaborative, and world-leading scientific enterprise.' The process includes three phases during which RTES will coordinate with program offices. This includes ensuring solicitations include appropriate language on RTES requirements, including assessment of technology risk level; and RTES 'due diligence' reviews before selection for award; and changes that occur during the life of a project that may trigger RTES review. Risk reviews use information disclosed to the agency as well as public and classified sources. Risk factors include ties to malign foreign talent recruitment programs, 'certain foreign funding sources', 'certain concerning behaviors associated with patenting', and ties to foreign entities or foreign collaborators on specified [certain U.S. restricted] lists 'or with specified characteristics.'

August 2024. Assists agency staff in assessing grant applications and ongoing awards for potential foreign interference. Factors considered include: (1) current or past participation in a malign foreign talent recruitment program, which is prohibited by law, (2) undisclosed current or prior funding from a foreign country of concern (FCOC), or connected entity (currently China, Russia, North Korea, and Iran (higher risk)) or other foreign country (lower risk) and, (3) Indicators of an undisclosed current or past affiliation with an institution or entity located in or connected to a FCOC (higher-risk/mitigation) or foreign country (lower-risk/mitigation). Per the matrix, mitigation is either required, recommended, suggested, or not required based on the timing of the engagement and if accurate and complete disclosure information was provided. Mitigation conditions include: (1) specific award conditions, (2) modification of terms and conditions of award, (3) suspension, termination, or withdrawal of an award, (4) conversion from advance payment to reimbursement, and (5) recovery of funds.