International Research Collaborations

Conducting Internationally-Sponsored Research and Working with International Researchers

The University of Chicago steadfastly supports our faculty and other investigators’ international research and collaborations, whether conducted overseas or in University laboratories. To that end, the Provost’s Office, together with University Research Administration, has compiled the following information to provide guidance and resources to UChicago researchers and administrators regarding the research-related compliance and disclosure obligations they may have when conducting research abroad or in the U.S. that involves non-US persons.

In general, Faculty should be cognizant of the increased scrutiny of information submitted to federal agencies, both in proposal applications and on RPPRs, as well as their other support, financial conflict of interest, biosketches, and outside appointment disclosures. These documents should be kept current and complete in compliance with all applicable University and local policies and procedures, and federal requirements.

Faculty members and others involved in research with questions regarding such disclosures, foreign affiliations, or any other issues related to their research efforts should contact Michael Ludwig, Associate Vice President for Research Administration & Director, URA ((773)702-8604; mrludwig@uchicago.edu ) or Jennifer A. Ponting, Executive Director of Sponsored Programs ((773) 834-5092; ponting@uchicago.edu ). Questions regarding individual grants and contracts should be directed to your assigned URA Pre or Post Award Research Administrator (available here) and specific questions regarding export compliance should be directed to Disrael Sanchez-Rodriguez, Export Control Compliance Manager ((773) 702-8601; dsanchezr@uchicago.edu).

Please understand that while this information is up to date as of this posting further clarifications may be forthcoming.  Please contact any manager in URA if you have questions about these requirements and check this website for up-to-date information.

1. Financial Conflict of Interest (University Policy)

Faculty and other investigators must disclose significant financial interests received (including from foreign governments, universities, and institutions), per the University of Chicago’s  Conflict Of Interest And Conflict Of Commitment Policy For Faculty And Other Academic Appointees. The definition of “significant financial interest” is set forth in the Policy, and includes “anything of monetary value that does or could reasonably be perceived to directly and significantly affect the design, conduct or reporting of funded research, or the performance of other Institutional Responsibilities, whether or not the value is readily ascertainable.” If you are unsure whether a particular interest or remuneration meets this definition, please contact Mallory Snyder, Director, Research Integrity ((773) 702-4857; mallorysnyder@uchicago.edu ).

The Policy also sets forth additional requirements for PHS-funded investigators regarding reimbursed or sponsored travel related to their University responsibilities, as described in greater detail below under “Reimbursed and Sponsored Travel".

a. It is the responsibility of each faculty member and other person covered by the Policy to comply with its terms. While those covered by the Policy must disclose certain financial interests and other arrangements to the University, sponsors may require additional disclosure to the University or to the sponsor directly. It is the responsibility of each faculty member and other person involved in research to understand and comply with any such additional disclosure obligations. 

b. For U.S. Public Health Service (PHS)  investigators, training on PHS-specific financial conflicts of interest (FCOI) requirements is available here

c. Disclosure is completed in the AURA COI system at the beginning of each fiscal year.  Disclosures should be updated throughout the year as new financial interests arise.

2. Federal Sponsor Disclosure and Approval Requirements

Several Federal agencies have recently revised or clarified their disclosure requirements to ensure federally-funded researchers disclose their relationships and activities with non-US institutions, organizations and funding agencies. They have also reiterated that failure to properly and timely disclose foreign relationships and activities may jeopardize current funding and PI-eligibility for future funding.

NIH-Specific Guidance

NSF-Specific Guidance

3. Hosting Visiting Researchers, Scholars and other Non-US persons

Non-US visitors (aka “foreign nationals”), including those for whom the University is the official sponsor or facilitator for visa purposes must be screened prior to arrival on campus, and, ideally in advance of receiving an invitation to campus, as their visits may implicate OFAC or Export Control regulatory restrictions.  The University currently screens Visiting Scientists, Visiting Scholars and BSD’s External Academic Research Scientists (EARS) Program. For all other visitors who will be involved in University research, screening is conducted upon request by contacting Marie Bejarano (mbejarano@uchicago.edu) in the Global Office or Disrael Sanchez-Rodriguez (dsanchezr@uchicago.edu), Export Control Compliance Manager, in University Research Administration.

Additional information on Export Control and Sanctions laws applicable to University research activities is available here.  URA also provides in-person training to provide a basic understanding of these legal regimes and how to comply. To schedule a training contact Disrael Sanchez- Rodriguez, Export Control Compliance Manager (dsanchezr@uchicago.edu). Self-guided trainings are also available on CITI here