Malign Foreign Talent Recruitment Programs
Broadly speaking, a Malign Foreign Talent Recruitment Program (MFTRP) is any program, position, or activity that includes compensation (in any form) provided by a foreign country to an individual, in exchange for that individual undertaking action or activities which would be prohibited by U.S. federal law, federal sponsor requirements, and/or institutional policy.
Please refer to National Security Presidential Memorandum-33 for the full text of the MFTRP definition.
Individuals participating in federal research are prohibited from participation in a Malign Foreign Talent Recruitment program. Principal Investigators are required to certify that they are not part of a MFTRP, and are responsible for ensuring that their research team members likewise do not participate in such a program.
- National Institutes of Health (NIH) prohibits participation in a MFTRP per OSTP ‘Guidelines’ Memorandum of February 14, 2024, and NIH agency Guidance of June 12, 2025.
- National Science Foundation (NSF) prohibits participation in MFTRP per Important Notice No. 149: Updates to NSF Research Security Policies.
The federal government’s definition of a MFTRP or “malign” program includes three main elements:
- Sponsored by a “Country of Concern”;
- Includes some form compensation or benefit (which does not have to be monetary, including the promise of a future benefit including in-kind contributions or honorary titles); and
- Includes one of more of the problematic indicators in the federal government’s definition of a “malign” talent program.
Foreign Countries of Concern currently include China, North Korea, the Russian Federation, and Iran.
If you have any questions related to MFTRPs, please contact GW's Office of Research Security at rsec
gwu [dot] edu.
Additional information can be found in the Guide for NIH Intramural Principal Investigators to Navigate International Interactions and Avoid Inappropriate Foreign Interference with Their Research.