Mitigating risk

These “Ten Key Points for MIT Faculty & PIs When Engaging Internationally” help faculty and PIs navigate international collaborations while minimizing risk.

The Institute has in place a systematic review process for considering formal collaborations (i.e., those bound by formal contractual relationships or agreements) with entities in countries judged to pose elevated risks – currently China, including Hong Kong; Russia; and Saudi Arabia. As part of your initial contemplation of such collaborations, please carefully consider the potential research benefits to you, to the other participants in the project, and – more broadly – to MIT, to the research community, and to the world. If, after making your initial benefits assessment, you remain interested in further exploring the proposed collaboration, the elevated risk process will be initiated on your behalf when you begin planning the project with the relevant department or office.

Informal collaborations (i.e., collaborations for which there is no written agreement and no required deliverables or funds exchanged) typically don’t go through MIT review processes. Before engaging in informal collaborations with peers or entities in other countries – especially in elevated-risk countries – please take advantage of the Informal International Collaborations (IIC) tool to seek advice on the increasingly complex federal laws, regulations, and agency requirements surrounding these collaborations.

Sit down with the members of your lab or research group on a regular basis to make sure they understand the norms and expectations for sharing information outside the group. Also, please make sure that your students know to consult with you first before they enter into international collaborations of their own – even informal ones. This PI discussion guide on research security and compliance can help support conversations with your group or advisees, and the Research Compliance team (research-compliance-help@mit.edu) within the Office of the Vice President for Research can also provide you with guidance.

Traveling internationally, especially to elevated-risk countries, can raise issues related to the protection of electronic devices and data, as well as export control, customs, and visa considerations. Please follow the relevant guidance. All travelers are strongly encouraged to borrow secure devices from IS&T’s enhanced loaner device program that minimizes administrative burden on the traveler.

MIT welcomes visitors from around the world.

• For short-term visitors to campus (those who would not hold an MIT appointment) from elevated-risk countries, please seek advice using the IIC tool before extending an invitation.
• For visiting students or scholars who would hold an MIT appointment, faculty and PIs do not need to take any additional action. An additional administrative review step has been added to the appointment and visa application process to ensure that appointments aren’t processed for individuals who are employed by Chinese military or security institutions, as recommended in the final report of the MIT China Strategy Group. In those rare instances where a proposed appointment may raise concerns, principal investigators will be advised of the issue.

Exercise caution and review information on potential risks. Know your conflict of interest reporting, outside professional activities reporting, and sponsor disclosure obligations before accepting compensation from foreign entities, especially from elevated-risk foreign governments.

Avoid participation in “malign foreign talent recruitment” programs that are designed to transfer technology or that offer payment or in-kind assistance in return for providing information, or that create other conflicts of commitment. Assess the risks of any talent recruitment program, and when in doubt, ask for guidance from MIT Research Compliance (research-compliance-help@mit.edu).

Avoid playing any organizational or administrative role, either with or without compensation, in programs that are designed to recruit and channel graduates specifically into jobs in elevated-risk countries.

Don’t hesitate to recommend MIT students or postdocs for positions abroad, but avoid writing letters of recommendation for non-MIT students in programs in which you have been paid to teach with a quid pro quo that you write such letters.

Please remember that you can always seek direct advice from the Research Compliance team (research-compliance-help@mit.edu) in the Office of the Vice President for Research.