A Message to Cornell University Faculty

From Emmanuel P. Giannelis, Vice Provost for Research, and Wendy W. Wolford, Vice Provost for International Affairs

Dear colleagues:

As you may recall, last year, we notified you of several federal agencies, including the National Institutes of Health (NIH), the National Science Foundation (NSF), and the U.S. Departments of Defense (DoD) and Energy (DoE) that have expressed growing concerns about foreign influence on the integrity of research conducted in U.S. institutions. The government maintains a high level of concern regarding potential misappropriation of federally funded research by foreign actors, particularly China.

Federal agency regulations and guidelines are evolving, but in general, there is increased emphasis on disclosure of foreign funding, employment, appointments, affiliations, parallel laboratories, conflicts of commitment, and financial conflicts of interest. The penalties for non-disclosure can be severe, sometimes resulting in FBI investigations and, in the most severe cases, arrests. A recent case at MIT highlights the importance of careful and comprehensive disclosure of all foreign commitments, collaborations, and compensations (see these pieces on the U.S. Justice Department website and the New York Times). 

Cornell’s commitment to global engagement and support for open, international collaboration remains unchanged. Cornell is equally committed to fulfilling the requirements for open and transparent disclosure to our federal sponsors. Below, we have provided links to various helpful resources, including required and recommended best practices for Cornell faculty and staff to help you understand and meet both Cornell and federal expectations for compliance and transparency. The requirements, recommendations, and resources listed below apply to work with foreign collaborators generally, whether in Ithaca, New York City, or abroad. 

• Foreign Collaborations and Support: This resource outlines federal requirements for the disclosure of all sources of support, appointments, affiliations, and consulting activity, observing appropriate security precautions when traveling, negotiating research collaborations with foreign entities, and screening visitors to Cornell.
• Engagement with China: FAQ: A helpful resource detailing requirements and resources for travel, shipments, collaborations and services, private consulting and teaching time, and other matters related to working with or in China. 
• Resources Available on Campus: Today’s most pressing and important research questions are global ones, and international collaboration is often key to rigorous research and impact. Therefore, to support our growing international portfolio while maintaining compliance and common-sense security measures, we highlight the host of resources available to the Cornell community.
• Guidelines on Ethical International Engagement: These guidelines are intended to help faculty members navigate collaborations with partners in other areas of the world, where unequal power relations and different cultural, social, and political norms may apply. Additionally, when there are concerns about violations of academic freedom or other core Cornell values in faculty international engagements, the guidelines can help faculty members carefully consider and develop an appropriate response with university leadership assistance.
• OSP’s September 2020 Roundtable – Disclosing Foreign Relationships and Activities: A recorded discussion of the impacts of the evolving landscape on research activities at Cornell. Download a copy of the presentation slides here.
• Pandemic Travel Policy, Guidelines, and Recommendations: All university-related international travel is prohibited until further notice. Though expected to be rare, faculty, staff, and graduate and professional school students may petition for a travel exception in accordance with the process described here if they believe the proposed university-related travel is essential for Cornell or essential for the continuation of their educational or scholarly program. All Cornell students, staff, and faculty engaging in approved international travel on Cornell business are required to register in the travel registry. 
• Export Control Resources: Compliance with export control laws is the responsibility of each individual, as well as the institution and Cornell, is committed to compliance. The export control website provides detailed information and resources to support the Cornell community in maintaining compliance. 
  • Note that when traveling to China, Russia, or Venezuela, export control regulations now require that items listed on the Commerce Control List and carried with you abroad must be reported to the U.S. government. Examples of items that must be reported include cell phones, cameras, laptops, computers, and most software programs installed on computers. This requirement applies regardless of the value of the item(s) or the fact that the item(s) will be abroad only temporarily. The required filing is an Electronic Export Information filed in the Automated Export System. Individuals traveling on behalf of Cornell are strongly encouraged to contact the Export Control Officer for assistance in completing this requirement. Find additional details here. 

Conclusion

Working, studying, and collaborating internationally offers benefits and opportunities, many of which are crucial to a world-class university such as Cornell. The landscape, however, can be unpredictable and overwhelming. If you have any questions or doubts about how to proceed, please contact the office of the vice provost for international affairs, the office of the vice president for research and innovation, or the office of general counsel.

Sincerely,

Emmanuel P. Giannelis
Vice President for Research and Innovation

Wendy W. Wolford
Vice Provost for International Affairs