Foreign Talent Recruitment Programs (FTRP) are an effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students. Individuals are recruited irrespective of citizenship or national origin and whether the role is full-time or part-time. Individuals may receive remuneration such as compensation, research funding, honorific titles, career advancement opportunities, promised future compensation, compensated travel or other considerations. 

Participation in a foreign talent recruitment program MUST be disclosed to Harvard Medical School through the Outside Activities Reporting Portal and MUST be disclosed to Federal Sponsors through Biosketches, Other Support Pages or similar. 

Many countries sponsor talent programs for legitimate purposes of attracting researchers in targeted fields, and many programs utilize legitimate means of attracting talent, including offering research fellowships and grants to incentivize researchers to physically relocate. However, some programs encourage or require unethical and criminal behaviors such as: Problematic terms and conditions or requirements are frequently associated with talent program participation.

Undisclosed obligations to a FTRP may have serious consequences, including prohibition of an individual from participating in federally sponsored research or lasting financial damages to the faculty member’s lab or institution.  Participation may also pose risks to U.S. national security. FTRP participants have faced charges of export-control law violations; economic espionage and theft of trade secrets; and grant and tax fraud.

Malign Foreign Talent Recruitment Program (MFTRP)

A foreign talent program is considered “malign” when it offers cash or in-kind compensation (complimentary foreign travel, honorary appointments, promised future compensation, research funding, etc.), in exchange for one of the following: 

  • Engaging in the unauthorized transfer of intellectual property, materials, data, or other nonpublic information;
  • Recruiting or training other talent recruitment program members, circumventing merit-based processes;
  • Establishing a laboratory or company or accepting a faculty position or other employment in a foreign country in violation of terms and conditions of a Federal research award;
  • Applying for and receiving research funding from the foreign institution’s government funding agencies with the foreign institution as the awardee, without disclosure to and approval from Harvard University;
  • Attributing awards, patents, publications, and projects to the foreign institution, even if conducted under a Federal research award, omitting Harvard University and/or the Federal funding agency; 

OR is characterized by contracts or agreements with:

  • Oppressive termination clauses;
  • Non-disclosure requirements; or 
  • Duplication of effort under Federal awards or conflicts of commitment with Federal awards 

AND is sponsored by:

As of May 1, 2024, current countries of concern are: China, Russia Federation, North Korea and Iran. This list will be updated as new information becomes available.

Prohibitions and Cautions:

Certification of Non-Participation:

  • Effective May 20, 2024 for all NSF proposal applicants and August 9, 2024 for all other sponsored funding applicants, all Covered Individuals (defined at Harvard as individuals flagged in GMAS as PI, Investigator or Senior/Key Personnel on a sponsored award) must certify annually.
  • The Science Experts Network Curriculum Vitae (SciENcv) which is currently mandated by the National Science Foundation (NSF), and recommended for use by other funding agencies uses the Biographical Sketch Common Form recommended by the Office of Science and Technology (OSTP) that includes the recommended certification (“I also certify that, at the time of submission, I am not a party to a malign foreign talent recruitment program”.
  • Questions about MFTRP certifications at HMS should be addressed to:


  • All Covered Individuals must disclose participation in any talent program or MFTRP in the Outside Activity and Interest Reporting (OAIR) system within 30 days of the start of the participation.
  • Participation in a Foreign Talent Recruitment Program must be disclosed to Federal Sponsors through Biosketches, Other Support Pages or similar. 
  • Harvard must disclose to DOE whether applicable personnel are participating in a foreign talent recruitment program.

Identification of Talent Program or MFTRP Participation:

Researchers are encouraged to carefully review all agreements and thoroughly vet all arrangements to ensure that they are aware of any participation in a talent program or MFTRP. 

The University has created a guide to help individuals identify if they are participating in or have been offered a role with a talent program or Malign Foreign Talent Recruitment Program. Appendix 1 of this document lists international collaboration activities deemed NOT to be a talent program or Malign Foreign talent Program activity.

If a researcher is unsure if an opportunity qualifies as a Foreign Talent Recruitment Program or a Malign Foreign Talent Recruitment Program, they should reach out to ORA’s or HMS’s Office for Academic and Research Integrity to discuss. HMS’s Outside Activities Team is also available to assess outside activity agreement compliance with University policy. Individuals engaging in outside activities are also welcome to consult with personal legal counsel.