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Dear Colleagues,

We are writing to update you on the second phase of the mandatory disclosures for Malign Foreign Talent Recruitment Program requirement from the National Science Foundation (NSF) that affects all Principal Investigators (PIs) and Co-Principal Investigators (Co-PIs) on NSF awards.

Effective June 9, 2025, all PIs and Co-PIs on NSF awards made on or after May 20, 2024, must complete an annual certification affirming that they are not a party to a Malign Foreign Talent Recruitment Program (MFTRP) in addition to Ð԰ɵ¼º½’s annual research conflict of interest disclosure. The CHIPS and Science Act of 2022 defines a as any program, position, or activity that is sponsored by a foreign country of concern that includes compensation in exchange for activities that may violate research security regulations.

Key Details:

• Who is affected: All PIs and Co-PIs on NSF awards made on or after May 20, 2024.
• What is required: An annual certification that the individual is not participating in an MFTRP.
• Where to certify: Certifications will be completed via Research.gov.
• When to certify: The certification process will begin June 9, 2025. 
• Impact of not certifying: To submit new proposals, annual reports, etc. via Research.gov certification must be completed. 
• Ongoing compliance: Follow-on annual certifications will be tied to the date of the first applicable award.

Please note that this requirement currently applies only to PIs and Co-PIs. NSF is developing a separate annual certification process for all senior/key personnel, which will be announced at a later date.

We encourage all affected individuals to log into Research.gov and ensure their profiles are up to date in preparation for this new requirement.

If you have any questions or need assistance, please contact Lacee Harris, PhD, Executive Director Research Compliance & Integrity (export@drexel.edu).

Thank you for your attention to this important compliance update.