International collaborations play an important role in scientific discovery, but they also carry disclosure responsibilities. Under the National Security Presidential Memorandum 33 (NSPM-33), federal agencies have adopted more standardized disclosure requirements related to foreign affiliations, research support and professional activities. The NSPM-33 Disclosure Matrix provides guidance on what information must be disclosed, where it should be reported, and when updates may be required. NSF serves as steward of the NSPM-33 disclosure guidance and common disclosure forms.

Recent enforcement actions demonstrate the importance of accurate and timely disclosures. In 2026, Ohio State University agreed to pay $2.1 million to resolve allegations that foreign affiliations and support associated with federally funded researchers were not appropriately disclosed to sponsoring agencies.

Case study 1: The unpaid foreign appointment

Scenario: Dr. Lawrence accepts an unpaid appointment as a Visiting Professor at a foreign university. He occasionally advises students, participates in seminars, and uses laboratory facilities during visits abroad. Because he receives no compensation, he assumes the appointment does not need to be reported.

Q: Does this need to be disclosed?

Most likely, yes. Under NSPM-33 guidance, foreign appointments, affiliations, and professional activities may require disclosure even when they are unpaid.

Research Security Takeaway: Unpaid does not necessarily mean undisclosable. Foreign titles, appointments, and affiliations may need to be reported.

Case study 2: Travel support from an international collaborator

Scenario: A faculty member is invited to present research at a foreign institution. The host organization pays for airfare, lodging, and meals.

Q: Does this need to be disclosed?

Most likely, yes. Travel support, access to facilities, equipment, personnel, or other in-kind contributions may need to be disclosed depending on sponsor requirements.

Research Security Takeaway: Support is not limited to direct funding. In-kind contributions and sponsored activities may also create disclosure obligations.

Case study 3: Reporting to the university but not to the sponsor

Scenario: A faculty member properly lists a foreign affiliation on an annual Financial Conflict of Interest disclosure. The information remains in institutional records but is never included in sponsor-required disclosures.

Q: Does this need to be disclosed?

Yes. Even though University reporting systems and sponsor disclosure requirements serve different purposes, there can be some overlap in disclosures to the university and funding agency, depending on the affiliation.

Research Security Takeaway: Reporting something to your institution does not automatically satisfy sponsor disclosure requirements.

Key questions for researchers:

• Do I have any foreign appointments or affiliations?
• Have I received foreign funding, travel support, or other in-kind support?
• Am I using facilities, equipment, or personnel provided by an international collaborator?
• Have I reported all required information both internally and to the sponsor?

For questions, email Jessica Convertine, research security officer and export compliance officer for Research and Innovation.

References

U.S. Department of Justice. Ohio State University Agrees to $2.1M Settlement to Resolve Allegations that it Failed to Disclose Employees’ Ties to the People’s Republic of China in Applications for Federal Research Funding. August 31, 2026.

National Science Foundation. NSPM-33 Implementation Guidance.