Compliance with federal regulations

The regulatory environment is becoming more focused on foreign activities, seeking greater transparency into their scope and substance as well as stepping up enforcement and levying large penalties for missteps, and the pace of new legislative activity around international transactions continues to be significant.

Major U.S. regulations that govern the conduct of our international activities include:

• Export controls.
• Import controls.
• Foreign Corrupt Practices Act.
• Anti-boycott laws.
• Office of Foreign Assets Control.

This list is non-exhaustive for the U.S., and the government(s) of a foreign sponsor will have different and possibly more onerous regulatory requirements. For more information, the Vice President for Research (VPR) Integrity and Compliance website also contains a wealth of information on working with non-U.S. collaborators and sponsors.

The U.S. Government, including the federal agencies that fund much of MIT’s research, has expressed serious concerns regarding inappropriate influence by foreign entities, government, or individuals on U.S. institutions and researchers.

The VPR’s page on foreign engagement provides examples of key concerns in this area to make the MIT community aware of processes that we have in place to mitigate undue foreign influence through disclosure and transparency — not to prevent or limit international collaborations. Some of those processes and tools include a CITI Program four-part course titled Undue Foreign Influence: Risks and Mitigations and an Informal International Collaborations (IIC) tool to report informal collaborations where there is no written agreement or exchange of funds.

The MIT Office of the General Counsel and VPR have jointly compiled a set of FAQs to assist the MIT community with common concerns regarding international activities at MIT. These answer common questions in topic areas including:

• External academic appointments and other outside professional activities.
• Grant review, co-authorship, and other customary academic activities in an international environment.
• Letters of recommendation and media interactions.
• International travel and conferences.
• The Entity List and other U.S. sanctions lists.