Resources

Overview

FOREIGN INFLUENCE COMPLIANCE RESOURCES

The following is a list of applicable laws, regulations, and additional resources available to better comprehend the nature of foreign influence compliance and how it relates to the University of South Florida.

Federal

The Higher Education Act (HEA) of 1965, Section 117, requires nonprofit colleges and universities in the United States to disclose their financial relationships with foreign entities, gift to or contracts with the University of South Florida, to ensure transparency and prevent undue influence or bias. The HEA requires the university to report gifts to and contracts with USF on a semi-annually, every calendar year. Failure to meet HEA reporting requirements can result in the loss Title IV funding, which enables the university to accept federal student loan funding from the U.S. Department of Education. The National Security Presidential Memorandum 33 (NSPM-33) is a presidential directive aimed to safe-guard U.S. funded scientific research from undue foreign influence, promoting global research collaboration while securing American research interests. NSPM-33 requires the university to implement a comprehensive research security program which encompasses cybersecurity, foreign travel security, export control training, and research security training. Failure to comply with NSPM-33 can result in the university’s inability to apply for and be awarded U.S. funded research grants from national funding agencies, such as the National Science Foundation, the National Institutes of Health, or the Defense Advanced Research Projects Agency, to name a few.

• Higher Education Act of 1965, Section 117 
• National Security Presidential Memorandum 33 (NSPM-33) 

Florida State Statutes

The following is a comprehensive list of Florida State Statutes pertaining to foreign influence legislation applicable to the University of South Florida. This legislation addresses the following foreign influence compliance areas: international cultural agreements, foreign gifts and contracts reporting, screening foreign researchers, foreign travel, and researchers’ disclosure of their outside activities and financial interests.

• International Cultural Agreements - Fla. Stat. §288.860 
• Foreign Gifts and Contracts - Fla. Stat §1010.25  
• Screening of Foreign Researchers - Fla. Stat. §1010.35  
• Screening of University Foreign Travel - Fla. Stat. §1010.36  
• Disclosure of Outside Activity & Financial Interests - Fla. Stat §1012.977  

Florida Board of Governors

The Florida Board of Governors (FLBOG) has issued regulation and guidance on foreign influence legislation, which provides institutions in the State University System (SUS) with compliance and submission guidance including semi-annual and annual reporting requirements of foreign gifts and contracts. In addition, it outlines the requirements for entering international cultural agreements with foreign countries of concern (FCOCs). Moreover, it establishes the screening requirements for both foreign research and research related staff on campus and foreign travel requests. This guidance document is updated periodically, to reflect changes in Florida legislation.

• FL BOG Regulation 9.012 - Foreign Influence - updated Sept 2023 
• FL BOG, Activity with Foreign Country of Concern Guidance - updated Oct 2023 
• FL BOG, Foreign Influence Guidance - Dec 2022 

University of South Florida

The following is information established to provide university stakeholders with additional guidance on applicable state legislation.

• USF Policy 0-027: FCOE for Public Officers and Employees; Compliance and Disclosure  
• USF Policy 0-030: Foreign Influence Compliance 
• USF World Feasibility Report for International Cultural Agreements  
• USF World Foreign Travel Guidance for Travelers