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Assess a foreign grant, donation, sponsored project, collaboration or investment by examining the whole relationship—not the funder’s nationality alone. Map money and in-kind support, affiliations, disclosure obligations, decision-making rights, access to research and data, and rights to intellectual property. Then check the rules that apply to the specific people, institution, project and transaction. The goal is to identify and address concrete risks while preserving legitimate international collaboration.
What counts as foreign support or influence?
A payment is only one part of the relationship. Support may also include equipment, personnel, lab space, software, visiting researchers, paid or unpaid appointments, outside employment, gifts with conditions, and participation in a foreign program. A grant routed through an intermediary may also require identifying the underlying funder and any relevant affiliations.
For U.S. federally supported research, disclosure requirements depend on the agency and award. NIH guidance covers research support, foreign components and financial conflicts for senior or key personnel; its disclosures help the agency assess possible duplication, time commitments and objectivity. NSF describes conflicts of interest and conflicts of commitment. NSPM-33 uses a broad concept of “other support.” These requirements are not interchangeable, so check the current instructions and award terms that apply to the proposal or project.
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Keep a consistent record of current and pending support and relevant affiliations, and reconcile it across proposals, progress reports and institutional records. An omitted appointment or in-kind contribution can matter even when no cash changed hands.
Which parts of an offer should you examine?
Read the agreement alongside the project plan. The central question is what the funder can direct, see, restrict or claim—not simply how much it contributes.
#1 Best Overall
| Area | Questions to ask | Evidence to review |
|---|---|---|
| Source and support | Who is the legal funder, who controls or owns it, and are there intermediaries? What cash and in-kind resources are included, and for how long? | Grant or investment documents, side letters, institutional records, appointment terms and descriptions of equipment or personnel support. |
| Governance and direction | Can the funder set priorities, appoint steering-board members, approve milestones or redirect the work? | Governance provisions, project plans, committee terms and approval rights. |
| Access | Who can use or receive research data, model weights, software, facilities, materials or access to researchers? Are there limits on onward sharing? | Data-use terms, access-control plans, facility rules, collaboration agreements and security procedures. |
| Publication and confidentiality | Can the sponsor delay publication, require approval, impose confidentiality restrictions or limit what can be disclosed? | Publication-review clauses, confidentiality provisions and any separate data or materials agreements. |
| Intellectual property | Who owns existing and newly created IP? Does the sponsor receive a license, option, exclusivity or rights to future outputs? | Background-IP schedules, ownership clauses, license terms, options and provisions covering later inventions or outputs. |
| Researcher obligations | Does the support overlap with other proposed work? Can the researcher meet all effort commitments, and could a financial interest affect research objectivity? | Current and pending support records, effort plans, outside-interest disclosures and institutional conflict-management arrangements. |
| Applicable rules | Which sponsor, institutional, national and sector-specific requirements apply? Is there a notification, registration, export-control or other review route? | Award conditions, institutional procedures and advice from the relevant compliance, legal or government office. |
These questions are a practical review framework, not a universal scoring system. The official guidance summarized here establishes no single numeric threshold for deciding that an offer is acceptable or unacceptable.
How to review a proposed offer
- Define the transaction and the work. Identify the recipient entity, legal funder and any intermediary; list the people and labs involved; and describe the AI research, intended outputs, relevant data, equipment and software. Determine whether the work is fundamental, applied, classified or otherwise restricted under rules that actually apply to it. There is no single AI-wide category in the cited guidance that determines risk or approval requirements.
- Inventory support and affiliations. Record cash, gifts, contracts, in-kind resources, appointments, outside employment, program participation and visiting personnel for relevant researchers. Preserve supporting documents and compare the inventory with agency and institutional disclosure records.
- Trace rights and access. Mark who can choose research priorities, sit on steering bodies, review publications, receive data or materials, access facilities or software, and own or license existing and future IP. Note exclusivity, options and restrictions as well as direct ownership.
- Check conflicts and capacity. Compare the proposed work with other supported projects; check whether the researcher’s time commitments are feasible; disclose relevant financial interests; and decide how the institution will manage any conflict without compromising objectivity.
- Identify the right review route. Check sponsor and award disclosure conditions, institutional research-security procedures and any applicable jurisdictional requirements. Ask the appropriate research-security, sponsored-programs, legal, export-control or technology-transfer office to review questions within its remit.
- Choose and document proportionate safeguards. Depending on the identified concern, consider correcting a disclosure, amending contract terms, limiting access to data or IP, setting conflict-management measures, or obtaining specialist advice. Record the specific risk, the evidence for it, the decision and why the selected measure addresses it.
How do U.S. and UK rules differ?
The U.S. and UK examples below address different legal questions. They are not a single cross-border approval process, and neither example establishes the result for every AI research arrangement. The relevant outcome depends on the location, transaction structure, award terms, entities, work and rights involved.
U.S. federally supported research
U.S. federal disclosure and research-security obligations depend on the agency, award and institutional procedures. NIH materials address other support, foreign components, conflicts and applicant and recipient responsibilities; NSF materials address research security and conflict concepts. Review the actual agency requirements rather than assuming that one agency’s forms or definitions govern another award. The cited sources do not determine whether a particular AI model, dataset, investor or output is subject to a specific restriction.
UK National Security and Investment Act
The UK NSI regime concerns qualifying acquisitions of entities or assets. Advance mandatory notification may apply to certain acquisitions of entities in specified sensitive sectors. Asset acquisitions are not automatically subject to mandatory notification, although some may be called in and voluntary notification may be an option. UK government research-sector examples explain that a foreign-funded project involving steering-board participation and entitlement to resulting IP can be a contemplated qualifying asset acquisition for assessment. Whether a particular arrangement falls within the regime requires case-specific analysis.
UK Foreign Influence Registration Scheme
FIRS is distinct from NSI screening. The relevant question is whether an arrangement involves activity at the instruction of a foreign state or a specified state-controlled organisation, and whether the scheme’s requirements apply. Foreign funding alone does not establish that a registration obligation exists. Check current Home Office guidance and seek advice about the actual arrangement.
UK export controls and NSI processes are also separate: satisfying one process does not necessarily satisfy the other. For a live transaction, seek current institutional and relevant-authority advice rather than treating this overview as a legal conclusion.
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Use a mission-focused, risk-balanced review tied to the project and transaction. NIST’s 2025 Safeguarding International Science: Research Security Framework states: “The U.S. science and research ecosystem retains its leadership by actively engaging with the global community through the conduct of mutually beneficial collaborative research and the welcoming of international scientists.” Safeguards should therefore address an identified control, conflict, disclosure or security concern rather than treat foreign participation by itself as proof of improper influence.
NSF research-security training also addresses disclosure and risk management while recognizing the value of international collaboration. Depending on the facts, a workable response may be a corrected disclosure, a clearer publication clause, defined access permissions, a limit on particular data or IP rights, or formal conflict management. If the risk cannot be resolved through feasible terms or safeguards, the institution can escalate the matter for a decision by the appropriate office.
What the available government figures do—and do not—show
The U.S. Government Accountability Office reported a National Science Foundation estimate of about $1.4 billion in federal R&D obligations with foreign entities in fiscal year 2020. GAO identified FY2020 as the most recent data available for that figure in its 2024 report, so it is a historical baseline, not a current spending total. GAO also described agency difficulties determining foreign ownership and matching some listed entities to funding records. As of March 2026, its recommendation for the Office of Science and Technology Policy to facilitate information sharing remained open. Those findings provide context for screening challenges; they do not establish that any individual foreign-funded project presents a problem.
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