Security Considerations for Foreign Talent Programs

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US Government Funding - Under the provisions of the US CHIPS and Science Act of 2022, effective August 9, 2024, federal agencies are prohibited from providing funding for any proposal in which a ‘Covered Individual’ (a term used for Principal Investigator (PI), Co-PI, Senior or Key Personnel, Investigator, etc.) is participating in a Malign Foreign Talent Recruitment Program (MFTRP).  The National Science Foundation (NSF) has established an effective date earlier than required and will implement this requirement for new proposals and awards as of May 20, 2024. For more details, see Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs.

Foreign Talent Recruitment Programs

A foreign talent recruitment program (FTRP) recruits and retains experts to support a country’s strategic development goals. In most cases, a researcher is contacted directly with an invitation to join the program.

While each talent program operates differently, generally foreign talent recruitment programs provide researchers with incentives, such as the following.

  • Research funding
  • Financial compensation and other remuneration
  • Resources such as labs, equipment, and other in-kind support
  • Employment opportunities including appointments at foreign institutions
  • Titles and awards

Unfortunately, malign foreign talent recruitment programs (MFTRPs) also exist. MFTRPs are an effort organized, managed, or funded by a foreign government, or a foreign government instrument or entity, to acquire Canadian funded scientific research or technology unethically or unlawfully by recruiting researchers or students, regardless of their citizenship or national origin.

A foreign talent program may be considered malign if it requires the participant to undertake the following activities as part of their participation.

  • Provide research results, data, technology, or other non-public information or intellectual property from funded research programs to the foreign state sponsoring the talent program
  • Recruit others to join the talent program
  • Establish a laboratory or company and take on individuals from specific institutions
  • Refrain from disclosing their participation in such a program to any Federal research agency or employing institution

Security Considerations

Before participating in a FTRP, keep the following considerations in mind.

  • University Policy: If participation in a FTRP involves any of the following then it is deemed to be a ‘major paid professional activity’ and requires one-up approval per the Policy on Conflict of Interest, Academic Staff.
    1. Teaching for remuneration outside the University, other than occasional lectures, whether at another academic institution or for a professional development programme
    2. A commitment to any individual project totaling more than 20 days in an academic year
    3. Any combination of paid professional activities that are likely to exceed 45 days during an academic year.
  • Federal funding: Researchers receiving Government of Canada funding are required to disclose foreign affiliations and funding. Failure to disclose foreign affiliations and funding may be considered a breach of the Tri-Agency Framework on the Responsible Conduct of Research.
  • Provincial funding: The Ministry of Colleges and Universities (MCU) considers participation in a malign foreign talent recruitment program (MFTRP) to be a high-risk affiliation that may put provincial funding in jeopardy.
  • International funding: International granting agencies may also have criteria concerning participation in talent programs. For example, in the United States (US), the National Science Foundation (NSF), National Institutes of Health (NIH), Department of Defense (DoD), the Department of Energy (DoE), and other US funders prohibit sponsored research personnel from participating in MFTRPs, as required by the CHIPS and Science Act of 2022 s. 10631.


  • Provide research security advice on participation in foreign talent recruitment programs
  • Provide support for visiting faculty, visiting PhD, and Post Doctoral fellow engagements

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