Dear Colleagues,
The University encourages faculty to participate in academic or scholarly activities that enhance the University’s strategic goals, advance faculty pursuits and support the broader scientific community.
We are writing to share the University’s recommendations regarding engagement and collaboration with a subset of institutions that are named on the Entity List (see link under “Collaborations”) published by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), as well as journals that are affiliated with an institution that is named on the “Entity List.”
According to BIS, the Entity List identifies persons and entities that are reasonably believed to be involved, or to pose a significant risk of being or becoming involved, in activities contrary to the national security or foreign policy interests of the United States.
Appointments. The University strongly recommends that faculty not accept a paid or unpaid appointment with an institution on the Entity List. In addition, if you choose to accept such a position, you must follow the University’s approval processes, disclose your role pursuant to the University’s Faculty Conflict of Commitment and Interest Policy and reporting processes, and disclose your role to applicable federal funding agencies through your Biographical Sketch. Note that serving as a Principal Investigator on behalf of another organization or entity requires specific approval by your Dean.
If you are considering an appointment with a foreign institution, follow the requirements of the Simultaneous Appointments at Other Institutions Policy (page 34), as well as the University’s guidance on international appointments. Reach out to your Dean to understand approval requirements, and to the Export Control Officer (Nicole Porter; export@rochester.edu) and the Research Security Officer (Joe Doyle; joe.doyle@rochester.edu) for restricted party screening assistance.
Journal Service. We ask that you carefully consider participation in any leadership role or role that includes compensation with any journal that has an affiliation with an institution on the Entity List. In addition, if you choose to serve for such a journal, you must disclose your role pursuant to the University’s Faculty Conflict of Commitment and Interest Policy and reporting processes, and disclose your role to applicable federal funding agencies through your Biographical Sketch.
We have recently learned that some journals are affiliated with, partnered with, or published on behalf of institutions that are named on the Entity List. One example is a set of journals published by Nature with the Light Publishing Group, which is associated with an institution on the Entity List, the Changchun Institute of Optics, Fine Mechanics and Physics.
Collaborations. Faculty should reach out the to the Export Control Officer (Nicole Porter; export@rochester.edu) prior to initiating a research collaboration with a foreign institution, especially if the collaboration is with an institution in Cuba, Iran, North Korea, China, Syria, Russia, and the following regions of Ukraine: Crimea, Donetsk, and Luhansk, or if the institution is named on the Entity List.
The Export Control Officer will assist with restricted party screening and can help identify whether certain activities are prohibited or require the University to first obtain a license from the federal government. The University is restricted in its ability to export items to institutions on the Entity List.
Risk Reviews of Fundamental Research Projects. Federal agencies have adopted processes to conduct risk reviews of fundamental research projects. These processes occur at the application stage and include the review of details such as a researcher’s paid and unpaid appointments, sources of research support, potential participation in malign foreign talent recruitment programs, and affiliations or collaborations with institutions on a U.S. restricted party list (such as the Entity List) for potential research security risks. An active appointment with an institution on the Entity List, or evidence that a faculty member has not disclosed an appointment with an institution on the Entity List, are issues that federal agencies will likely flag as part of their risk review processes. Certain agencies (especially defense or defense-adjacent agencies) may also flag past and current publications when the researcher has co-authored with individuals from institutions on the Entity List.
If you have questions about engagement with institutions on the Entity List, you may reach out to Export Control Officer Nicole Porter (export@rochester.edu) and Research Security Officer Joe Doyle (joe.doyle@rochester.edu) with your questions.
Thank you,
Steve Dewhurst, PhD
Vice President for Research
Nicole S. Sampson
Provost and Chief Academic Officer
University Professor of Chemistry