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Malign Foreign Talent Recruitment Program Certifications to Federal Funding Agencies

Federal funding agency requirements for certifications related to participation in Malign Foreign Talent Recrutiment Programs are outlined here.
As a reminder, UA’s Conflicts of Interest & Commitment Policy prohibits participation in malign foreign talent recruitment programs. More information is available here: Malign Foreign Talent Recruitment Program Prohibition.

Individuals participating in a Malign Foreign Talent Recruitment Program are prohibited from participating in projects selected for federal funding under DOE notices of funding opportunities (NOFOs).

 

At Application Submission

  • Covered Individuals must certify they are not currently participating in a malign foreign talent recruitment program (MFTRP). This certification is located on the Common Forms in SciENcv.

 

  • The Research Security Program must provide the identity of all principal investigators, project managers, and covered individuals who are a party to any Malign Foreign Talent Recruitment Program (MFTRP).
  • UA must certify that each covered individual has been made aware of the MFTRP prohibition and complied with the certification requirement via the Current and Pending Support disclosure.

 

During Project

  • Covered Individuals must notify UA by updating their disclosure certification in eDisclosure and DoE if there are any changes to your MFTRP participation status.

 

  • The Research Security Program must exercise ongoing due diligence to reasonably ensure that no individuals participating on the DoE-funded project are participating in a MFTRP
  • The Research Security Program must notify DoE within five business days upon learning that an individual on the project team is or is believed to be participating in a malign foreign talent recruitment program

DoW is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program.

Individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NIH grant or cooperative agreement.

 

At Time of Application

  • Senior/Key Personnel must certify they are not a party to a malign foreign talent recruitment program on their Common Form for Biographical Sketch, attached on the R&R Senior/Key Person Profile (Expanded) Form.

 

  • The AOR must certify that all individuals identified by the applicant as senior/key personnel have been made aware of and have complied with their responsibility under that section. This certification is via the AOR signature on the face page of the application.

 

Annual Certification

  • Senior/Key Personnel must certify annually to their participation or non-participation in an MFTRP by uploading a certification statement in Section G.1, Special Notice of Award and Funding Opportunity Announcement Reporting Requirements as a flattened PDF file. The file for each senior/key person must be named ‘MFTRPcert_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person. certification.

    An RPPR Resources is available here: https://research.arizona.edu/administration/managing-projects/reporting#ProgressReports

Individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NSF proposal or on any NSF award made after May 20, 2024.

 

At Time of Application

  • Senior/Key Personnel must certify that they are not a party to a malign foreign talent recruitment program.

 

  • UA must certify that all individuals identified as senior/key personnel have been made aware of and have complied with their responsibility under that section to certify that the individual is not a party to a malign foreign talent recruitment program.

 

Annual Certification

  • Principal Investigator (PI) or co-PI on an active NSF award made on or after May 20, 2024, must certify annually via Research.gov to their participation or non-participation in an MFTRP. When you are required to certify, a pop-up message will display in Research.gov after you sign in to notify you that you must complete your MFTRP annual certification and what steps you need to take in Research.gov to complete the certification.

    Additional information on this process can be found here: nsf.gov/research-security

  • Covered Individuals must certify they are not party to a malign FTRP and must recertify annually for the duration of the award.

 

  • Applicants who either are currently or have in the past 10 years participated in malign FTRPs are prohibited from working on projects supported by R&D and S&T awards

 

  • The Research Security Program must provide any supporting documentation, including copies of contracts, grants, or any other agreement, specific to foreign appointments, employment with a foreign institution, participation in a FTRP, and other information reported as current and pending support for all applicants in an application.

Notification of UA's Malign Foreign Talent Recruitment Program (MFTRP) Prohibition and federal agency MFTRP certification requirements were sent to "researchers" on:

 

  • May 12, 2026

 

 

"Researchers" means anyone with a "yes" response to this question in eDisclosure: Are you directly or indirectly involved in any research at UArizona? This includes, but is not limited to, being listed on any funding proposal, awarded grant, IRB, or IACUC submission.