International Activities Involving Countries of Concern

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

Relationships and activities with Foreign Persons based outside the United States in a Country of Concern as described in Section 238(b)(1) of the Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 (Public Law 118-159). This includes gifts from entities associated with a Country of Concern and travel to a Country of Concern for professional purposes.  Please note that this includes but is not limited to 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; sharing of research facilities, resources or data; sharing of technical know-how; any financial or in-kind contribution intended to produce a research product; sponsorship or facilitation of research fellowships, visas or residence permits; joint ventures, partnerships, or other formalized agreements for the purpose of conducting research or sharing resources, data, or technology; inclusion as consultant, advisor, or member of advisory or review boards;  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.  Please see Texas A&M Rule 15.01.03.M1 Financial Conflicts of Interest in Sponsored Research, System Regulation 15.01.03 Financial Conflicts of Interest in Sponsored Research, Texas A&M Standard Administrative Procedure 15.99.99.M0.02 Conflict of Commitment, Texas A&M Rule TAMU Rule 31.05.01.M1 Faculty Consulting and External Employment and System Regulations  31.05.01 – Faculty Consulting and External Professional Employment and 31.05.02 – External Employment .  See FAQ 6 for additional requirements pursuant to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations and University Rule 15.05.04.M1

1. Guidance is available in System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations and University Rule 15.05.04.M1
2. It is best to contact the RESEC for current guidance on the above specific countries and other countries

1. Texas A&M 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 accuracy of these disclosures to the institution.

1. System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations and University Rule 15.05.04.M1
   1. All System member employees- including Graduate Teaching Assistants (GAT) and Graduate Research Assistants (GAR)
2. System Regulation 15.01.03 Financial Conflicts of Interest in Sponsored Research and Texas A&M Rule 15.01.03.M1 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. Texas A&M Standard Administrative Procedure 15.99.99.M0.02 Conflict of Commitment
   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
   6. Graduate student academic employees including, but not limited to, teaching assistants, instructional assistants, and research assistants
4. System Regulations 31.05.01 Faculty Consulting and/or External Professional Employment and Texas A&M Rule 31.05.01.M1 Faculty Consulting and/or External Professional Employmentmailchimp
   1. Full-time faculty members for activities directly related to their academic and professional discipline
5. 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
6. University SAP 21.01.03.M0.02 Foreign Travel
   1. All university employees and students traveling on university business or will be traveling with a university owned or managed device.
7. System Regulation 12.99.01 Faculty Development Leave
   1. Those faculty members who meet the eligibility requirements as listed in the FDL regulation

1. High Risk Global Engagement:  contracts with one or more Foreign Persons based outside the United States in a Country of Concern. Contracts that require participation with Foreign Persons based outside the United States in a Country of Concern are also considered a High Risk Global Engagement for purposes of Regulation 15.05.04.
2. High Risk International Collaboration:  relationships and activities with Foreign Persons based outside the United States in a Country of Concern as described in Section 238(b)(1) of the Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 (Public Law 118-159). This includes gifts from entities associated with a Country of Concern and travel to a Country of Concern for professional purposes. This includes 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; sharing of research facilities, resources or data; sharing of technical know-how; any financial or in-kind contribution intended to produce a research product; sponsorship or facilitation of research fellowships, visas or residence permits; joint ventures, partnerships, or other formalized agreements for the purpose of conducting research or sharing resources, data, or technology; inclusion as consultant, advisor, or member of advisory or review boards; 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, Material Transfer Agreements (MTA) and dual research agreements).
5. Please note that certain international collaborations fall under additional System regulations as follows.  Any specific questions relevant to each regulation are addressed in these FAQs.
   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 University Rule 15.05.04.M1.
   2. Texas A&M Rule 31.05.01.M1 Faculty Consulting and/or External Professional Employment and System Regulation 31.05.01 Faculty Consulting and/or External Professional Employment
   3. System Regulation 31.05.02 External Employment,
6. Only authorized officials are able to sign agreements on behalf of the University pursuant to University Rule 25.07.99.M1.  Academic agreements are approved by the Vice President for Academic and Strategic Partnerships, or designee.  Research Agreements are approved by the Vice President for Research, or designee.
7. Shipments (including hand-carry) to Countries of Concern, regardless of whether contracts or collaborations are involved.

1. Activities that do not involve a Country of Concern
2. It is important to note that activities that do not involve Countries of Concern may be subject to another review and approval process described in FAQ 5.

1. Presently there are four Countries of Concern as identified by RSO as it pertains to this regulation: China (including Hong Kong and Macau), Cuba, Russia, Iran, North Korea, and Venezuelan politician Nicolás Maduro (Maduro Regime). 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 U.S. 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 U.S. government annual reports to Congress and guidance from federal partners including the Defense Counterintelligence and Security Agency.  Countries of Concern are reviewed quarterly.

Relationships and activities with Foreign Persons based outside the United States in a Country of Concern as described in Section 238(b)(1) of the Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 (Public Law 118-159). This includes gifts from entities associated with a Country of Concern and travel to a Country of Concern for professional purposes. This includes 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; sharing of research facilities, resources or data; sharing of technical know-how; any financial or in-kind contribution intended to produce a research product; sponsorship or facilitation of research fellowships, visas or residence permits; joint ventures, partnerships, or other formalized agreements for the purpose of conducting research or sharing resources, data, or technology; inclusion as consultant, advisor, or member of advisory or review boards; 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.

1. Visiting scientists from Countries of Concern are 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 as outlined in Standard Administrative Procedure 15.99.99.M0.02 Visiting Scholars Not Involved in an Employer/Employee Relationship with Texas A&M University.   
2. Visiting Scholars affiliated with an entity on the list (Section 1286 List ) will be denied.

Students will be allowed. Student activities related to research may be subject to other reviews, such as export control compliance.

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.

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 RESEC  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.

1. The proposed collaboration should be submitted to the RESEC 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. If the collaboration is not part of your normal duties and/or if you are receiving compensation, the activity must be submitted for review and approval under Texas A&M Rule 31.05.01.M1 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.  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.

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 RESEC  pursuant to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

1. Representation will depend on the individual and their affiliations and must be submitted to RESEC for approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations. 
2. Representation from entities on the list (Section 1286 List ) will not be approved.

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.  More information may be found on our Visiting Scholars webpage.
2. Visiting Scholars affiliated with an entity on the list (Section 1286 List ) will be denied.

1. The proposed collaboration should be submitted to RESEC 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 (Section 1286 List ) will be denied.
3. If the collaboration is not part of your normal duties and/or if you are receiving compensation, the activity must be submitted for review and approval under Texas A&M Rule 31.05.01.M1 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.

If the journal is located in a country of concern, it must be submitted to RESEC for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

No, the rules do not change with respect to disciplines. Some disciplines may have elevated risks as compared to others.

1. Any collaboration from a country of concern must be submitted to RESEC 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 (Section 1286 List) will be denied.
3. If the collaboration is not part of your normal duties and/or if you are receiving compensation, the activity must be submitted for review and approval under Texas A&M Rule 31.05.01.M1 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.

1. No, if it is hosted by entities on the list (Section 1286 List ).
2. For other entities in Countries of Concern, reviews are conducted as part of the prior approval requirement of University SAP 21.01.03.M0.02 Foreign Travel.  The travel will require prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.
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 RESEC for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

No, but if the conference is located in a country of concern or 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 RESEC for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

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 RESEC for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

1. The proposed collaboration from a country of concern must be submitted to RESEC  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 (Section 1286 List ) will be denied
3. If the activity is not part of your normal duties of if you are receiving compensation, the activity must be submitted for review and approval under Texas A&M Rule 31.05.01.M1 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.

1. All faculty-led education abroad trips must have their travel pre-approved by the University through Emburse pursuant to University SAP 21.01.03.M0.02 Foreign Travel.  As part of the Emburse process, the trip will be reviewed by RESEC, 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 (Section 1286 List ) will be denied
3. If the activity is not part of your normal duties and/or if you are receiving compensation, the activity must be submitted for review and approval under Texas A&M Rule 31.05.01.M1 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, and will require approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

Prior to serving as an advisor/mentor/graduate committee to a graduate student located in a country of concern, it must be submitted to RESEC for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

1. If it is hosted by entities on the list (Section 1286 List ), it is not allowed.
2. For other entities in a country of concern, reviews will be conducted as part of the prior approval requirement of University SAP 21.01.03.M0.02 Foreign Travel and approval is 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 RESEC  for review and prior approval pursuant to System Regulation 15.04.04 High Risk Global Engagements and High Risk International Collaborations, and University Rule 15.05.04.M1.

1. Any known co-author that you are directly collaborating with that is located in a country of concern must be submitted to RESEC  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 (Section 1286 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 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.

1. If it involves entities on the list (Section 1286 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 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.

1. Prior approval is required for all foreign travel pursuant to University SAP 21.01.03.M0.02 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 RESEC for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

1. If it involves entities on the list (Section 1286 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.

1. If it involves entities on the list (Section 1286 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.

1. If it involves entities on the list (Section 1286 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.

No, provided that no more than a nominal amount of the employees’ time is required, and it is within the faculty members’ normal duties and responsibilities.

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.

1. Financial Conflicts of Interest:  Requirements are outlined in Texas A&M Rule 15.01.03.M1 Financial Conflicts of Interest in Sponsored Research and System Regulation 15.01.03 Financial Conflicts of Interest in Sponsored Research.  It should be noted that each sponsor also has their own set of disclosure requirements pertaining to international collaborations.
2. Conflict of Commitment:  Requirements are outlined in Texas A&M standard administrative procedure 15.99.99.M0.02 Conflict of Commitment. 
3. External Employment:  Requirements are outlined in Texas A&M 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 31.05.02  External Employment. 
4. Global Engagements:  Requirements are outlined in System Regulation 15.04.04 High Risk Global Engagements and High Risk International Collaborations and University Rule 15.05.04.M1.

No, as long as there have been no changes to the activities as listed in the approved FDL.  Any new international activities and/or collaborations that arise as part of the FDL will require further review. International travel that is part of the FDL must be routed through Emburse for review.

1. University SAP 21.01.03.M0.02 Foreign Travel requires prior approval for all foreign travel pertaining to official university business.  If traveling for personal purposes but taking TAMU owned equipment, prior approval is also required.
2. If working remotely in an international location, see also the International Alternate Work Locations Standard Administrative Procedure- 33.06.01.M0.03.pdf
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 are subject to System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

None

If the journal is headquartered in a country of concern the activity (vs. each submission) must be submitted annually to RESEC for prior approval under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

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 students’ name on your NSF COA table.

Yes, disclosure requirements under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations, are based on employment status rather than the capacity in which the collaboration is taking place.

Yes, prior approval is required under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations.

While all international shipments require prior export control review, please note that  prior approval is also required under System Regulation 15.05.04: High Risk Global Engagements and High Risk International Collaborations for any shipment to a country of concern.

Texas A&M Research Security and Export Controls Office:  exportcontrols@tamu.edu