In Short

The Situation: Foreign influence in U.S.-funded scientific research has been the subject of increased scrutiny and federal enforcement over the last four years, culminating in January 2021, when the Trump administration issued National Security Presidential Memorandum 33 ("NSPM-33"). NSPM-33 requires all federal research funding agencies to strengthen and standardize disclosure requirements for research and development awards, as well as research security measures at major institutions receiving federal funds.

The Result: The White House Office of Science and Technology recently released guidance implementing NSPM-33, including detailed disclosure and security requirements. These requirements will impact every researcher and research institution applying for federal scientific research funding.

Looking Ahead: Research institutions—including private companies receiving federal research dollars—should review the guidance and ensure that their policies, including training, compliance and research security functions, conform with these upcoming federal requirements.

On January 4, 2022, the White House Office of Science and Technology ("OSTP") released guidance for federal agencies to implement National Security Presidential Memorandum 33 ("NSPM-33"). Issued in the final days of the Trump administration, NSPM-33 requires U.S. research funding agencies to strengthen and standardize procedures for protecting U.S.-funded scientific research from foreign exploitation. The...

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