About Research Security
About Research Security at Emory
The White House Office of Science and Technology Policy released the National Security Presidential Memorandum 33 in January 2022. The memorandum requires federal funding agencies to expand disclosure requirements of grantees, requires grantees to operate research security programs, and mandates agencies to implement other research security protections. Federal funding agencies are rapidly releasing new, expanded, and/or revised processes, procedures, and requirements to comply with NSPM-33.
Emory is required to have a research security program as we receive more than $50 million in annual federal research funding. The Research security program at Emory aims to provide ongoing support to researchers to continue and enhance international research affiliations, engagements, and collaborations. We realize that navigating the many regulatory requirements related to foreign travel, disclosure compliance, and data protection measures, to name a few, can be cumbersome and challenging. Our team is here to help and assist so Emory’s global research footprint can continue to expand and flourish.
Additional Information
National Security Presidential Memorandum 33 (NSPM-33)
NSPM-33 is the impetus for Emory’s Research Security Program. It was issued on January 14, 2021 by the President of the United States and instructed the U.S. research enterprise to adopt certain research security measures. The objective of the Memorandum is to “strengthen protections of United States Government-supported R&D against foreign government interference and exploitation” while preserving the institution of global research collaborations. On January 3, 2022, the National Science and Technology Council released implementation guidance for research institutions in five key areas:
- Disclosure requirements and standardization;
- Digital Persistent Identifiers (see the Cybersecurity and Data Protection section of this webpage);
- Consequences for violation of disclosure requirements;
- Information sharing; and
- Research Security programs.
Conflict of Interest (COI) and Conflict of Commitment (COC)
Emory researchers with foreign engagements may be required to disclose certain information to the University’s COI-COC office and federal funding agencies.
COI: PIs and other investigators who are responsible in some way for the design, conduct, or reporting of sponsored research, gifts from external donors, or material transfer agreements must disclose the details of such activities to the COI-COC office. The information to be filed will depend on the source of funding. This is done in eDisclose.
COC: All faculty, regardless of effort, are required to disclose annual reports and external activity reports. This is done in eDisclose.
Contact the COI-COC office for more information.
Activities with any international nexus may be impacted by U.S. export controls and sanctions regulations, including:
- Activities involving actual export or transmission from the U.S. to a foreign destination of information, technologies, and commodities;
- Release of export-controlled information or technology to Foreign Persons in the U.S. or abroad, commonly referred to as deemed exports;
- Activities involving entities or individuals listed on restricted or prohibited party lists; and
- Activities or transactions in countries or involving nationals of countries against whom the U.S. has placed economic and trade-related embargoes. Comprehensively embargoed destinations include Iran, Cuba, Syria, North Korea, and the Crimea region of Ukraine.
In an academic and research setting such as Emory's, activities that can fall in one or more of these broad categories include activities related to international collaborations, international shipping, international travel, hosting international visitors, employment of non-immigrant visa holders, conducting research which has restrictions on publications or Foreign Persons' participation, and conducting research which makes use of export-controlled inputs.
Contact the Export Control Office for more information.
Foreign travel pursuant to a foreign engagement must be disclosed in accordance with Emory’s Foreign Travel Policy. This is done in eDisclose. The travel may be reviewed for compliance with funding agency policies, export controls, and other areas. Travel to sanctioned and high-risk destinations (i.e., Iran, Cuba, Syria, North Korea, Ukraine, and Russia) may require approval not only from the University but from the government.
Emory researchers traveling abroad may receive a research security briefing and/or loaner laptop, depending on the circumstances.
Contact the Research Security Office directly for more information.
Foreign Disclosures
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Intellectual Property and Tech Transfer
Research security also entails protecting the intellectual property (IP) of the University and its researchers. The Office of Technology Transfer (OTT) is responsible for licensing IP and seeking patents/copyrights as needed. Under Emory Policy 7.6, the University owns IP created or developed in the course of faculty members’ normal duties, even when that IP arises from employment at another institution or company. Researchers are required to disclose inventions to OTT accordingly.
Contact OTT for more information.