High Risk Global Engagements and High Risk International Collaborations

Approved March 7, 2023

Revised May 18, 2026

Next Scheduled Review: May 18, 2031

Supplements System Regulation 15.05.04

Rule Summary

Texas A&M Engineering Experiment Station (TEES) encourages its employees to establish global engagements in the pursuit of mutually beneficial fundamental scientific inquiry, cultural, or educational opportunities. These activities strengthen the academic and research programs and are fundamental to the TEES’s educational system. However, such engagements must be considered in a risk framework. This rule is required by System Regulation 15.05.04, High-Risk Global Engagements and High-Risk International Collaborations.

Procedures and Responsibilities

1. GENERAL

- Prohibitions and Reporting
- 1.1 – Malign Foreign Talent Recruitment Programs -TEES employees are prohibited from participating in Malign Foreign Talent Recruitment Programs (MFRTPs). Any employee who receives solicitations to participate in MFTRPs must notify the TEES Office of Research Compliance (RC). TEES RC will report such solicitations to the System Research Security Office (RSO) pursuant to System Regulation 15.05.04.
- 1.2 – Confucius Institutes -TEES is prohibited from maintaining contracts or agreements with a Confucius Institute.
- 1.3 – Gifts -TEES employees are prohibited from accepting gifts from a Country of Concern. Employees must report to TEES RC any activities where they are approached by groups representing a Country of Concern that offer gifts or travel. TEES RC will submit such solicitations to System RSO. If TEES wishes to accept a gift, whether directly or indirectly from a citizen of a foreign adversary, TEES will route the request through the System Regulation 15.05.04 process.
- 1.4 – TEES employees are prohibited from entering into High Risk Global Engagements and participating in High Risk International Collaborations with entities on the most recent list developed pursuant to Section 1286 of the National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232) as amended.
- 1.5 – Travel – All professional travel to a Country of Concern must be reviewed through the System Regulation 15.05.04 process, which is facilitated by TEES RC when received through Emburse. All employees must report personal travel to Countries of Concern in Workday.
- 1.6 – Employees with federally funded sponsored awards or proposals may be required to report High Risk Global Engagements and High Risk International Collaborations to their federal sponsors, regardless of whether the activity is in support of or being conducted on the federally sponsored research award. Agency-specific procedures for disclosure must be followed.
- 1.7 – Federal funding agency research security inquiries for TEES proposals and awards must be forwarded to TEES RC for review and response in coordination with the EO, System RSO, and others as deemed necessary.

2. DESIGNATED OFFICIAL

- The TEES Empowered Official(s)(EO), pursuant to TEES Rule 15.02.99.E1, serve(s) as the TEES designated official(s) for high-risk global engagements and high-risk international collaborations.

3. HIGH RISK GLOBAL ENGAGEMENT AND HIGH-RISK INTERNATIONAL COLLABORATION ADMINISTRATION

- 3.1 – Prior to engaging in High Risk Global Engagements and High Risk International Collaborations, the activity must be routed to TEES RC for reviews of any potential conflicts of commitment, conflicts of interest, export control, research security or undue foreign influence concerns.
- 3.2 – High Risk Global Engagements and High Risk International Collaborations must be submitted to TEES RC a minimum of 30 business days in advance of the proposed start date due to the extended review and approval requirements and to meet the required submission timeline to System RSO. For those activities that require prior approval of a supervisor, department head, dean, or other authorization, this must be obtained prior to TEES RC review in order to facilitate meeting the required deadlines.
- 3.3 – The TEES EO has the authority to deny High Risk Global Engagements and High Risk International Collaborations. If the EO does not approve the activity, a courtesy copy of the request will be provided to the System RSO.
- 3.4 – Any High Risk Global Engagements or High Risk International Collaborations not initially denied by the EO will be submitted to the System RSO for review pursuant to System Regulation 15.05.04.
- 3.5 – Once a final determination is provided by the System RSO and the TEES EO, TEES RC will notify the TEES involved parties. Mitigating measures will be communicated by TEES RC.
- 3.6 – Approvals for High Risk Global Engagements or High Risk International Collaborations are valid for the duration of the contract or collaboration. If any amendments are made to the contract or collaboration, a new review is required.
- 3.7 – TEES RC reviews and monitors High Risk Global Engagements and High Risk International Collaborations. Any High Risk Global Engagement or High Risk International Collaboration that proceeds without prior approval from TEES RC and others in accordance with this rule will result in disciplinary action ranging from a letter of expectation up to and including termination.

4. TRAINING

- Employees involved in High Risk Global Engagements and High Risk International Collaborations are required to complete export controls training at least once every two years and research security training annually.