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Assess foreign funding for AI research by examining the whole relationship—not just who sends the money. Identify the funder and its affiliations, every cash and in-kind contribution, the rights it receives over research and intellectual property, the access it gains, and the researchers’ disclosure and time commitments. Then check the specific sponsor rules and laws that apply to the people, institution, project, and transaction. Foreign involvement alone does not establish improper influence; review the concrete risks and use proportionate safeguards.
What should an assessment cover?
A grant, gift, investment, or collaboration can create obligations or access that are not apparent from its cash value. Start with the complete arrangement: the legal funder, any intermediary, the recipient, the project, the people involved, and all connected agreements. Include current and pending support, not only the offer under review.
- Support and affiliations: cash, conditional gifts, contracts, equipment, personnel, lab space, visiting researchers, appointments, outside employment, and participation in foreign programs.
- Governance and influence: who sets research priorities, sits on steering bodies, approves or delays publication, imposes confidentiality, or can change the work.
- Access: who can reach researchers, facilities, data, software, materials, systems, and research results—and under what conditions.
- Intellectual property: ownership, licenses, options, exclusivity, and rights over both existing IP and future outputs.
- Researcher obligations: effort and time commitments, possible overlap with other funded work, relevant financial interests, and disclosure duties.
- Applicable rules: sponsor and award terms, institutional policies, and the laws governing the transaction and research.
There is no single AI-wide risk category in the official materials cited here. Whether a project is fundamental, applied, classified, or otherwise restricted—and what controls follow—depends on its facts and the applicable rules.
How to conduct the due diligence
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Define the transaction and research
Write down the legal funder and any intermediary, the proposed recipient, the researchers and labs involved, the AI work and intended outputs, relevant datasets, equipment and software, and any restrictions already in place. Gather the proposal, award or contract, side letters, and related agreements so the assessment covers the whole arrangement rather than a summary of the payment.
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Inventory support and affiliations
For relevant senior or key personnel, record current and pending support, paid or unpaid appointments, outside employment, foreign affiliations, program participation, visiting personnel, and in-kind resources. Reconcile the inventory against proposals, progress reports, and institutional records, and retain the documents used. Disclosure definitions differ by sponsor: NIH, for example, addresses other support, foreign components, and financial conflicts for senior/key personnel; consult the applicable award instructions rather than assuming one agency’s categories apply everywhere.
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Read for control, access, and rights
Translate each contract term into a practical question: Who chooses priorities? Can the funder direct or steer work, participate in a board, receive nonpublic data or materials, access a lab or software, restrict publication, or claim ownership or a license to results? Check whether options, exclusivity, or rights to future IP could give the funder leverage beyond the stated project. In the UK, Cabinet Office NSI Act guidance gives the example of a foreign-funded research project with steering-board participation and an entitlement to resulting IP as a contemplated qualifying asset acquisition for assessment; that example is a reason to examine the terms, not a conclusion that every such project triggers notification.
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Check conflicts and capacity
Compare the proposed work with existing support to identify duplication. Confirm that each researcher can meet all effort and time commitments, and disclose relevant financial interests under the applicable rules. NIH says it uses disclosures to evaluate possible duplication, time allocation, and objectivity; NSF guidance addresses conflicts of interest and commitment. The institution should determine whether a conflict needs management and how research objectivity will be protected.
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Identify jurisdiction-specific routes
Determine where the recipient and relevant entities are located, what the transaction actually transfers, and which sponsor and government requirements apply. Keep disclosure obligations, investment screening, registration, sanctions, and export controls distinct; satisfying one process does not necessarily satisfy another. The U.S. and UK examples below illustrate different regimes, not universal legal advice.
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Select and record proportionate safeguards
Choose measures that address identified concerns and preserve legitimate collaboration where feasible. Depending on the facts, those may include correcting disclosures, amending contract terms, limiting access to data or facilities, clarifying IP rights, managing conflicts, or seeking specialist or government advice. Record the specific control, conflict, disclosure, or security issue, the evidence for it, the chosen mitigation, and why that mitigation is adequate. Do not treat nationality alone as proof of risk.
How do the U.S. and UK rules differ?
The regimes below address different questions. U.S. federal research-disclosure and institutional research-security requirements are not the same as UK investment screening or foreign-influence registration.
| Regime | What it addresses | What to check |
|---|---|---|
| United States: federal research disclosures and security | Disclosure and research-security obligations associated with federally supported research; agency and award conditions govern the relevant requirements. | Review the actual award terms, agency instructions, and institutional procedures. NIH’s disclosure guidance covers other support, foreign components, conflicts, and applicant and recipient responsibilities. NSF provides research-security resources and training. |
| United Kingdom: National Security and Investment (NSI) Act | Screening of certain qualifying acquisitions of entities in specified sensitive sectors, and potential scrutiny of qualifying acquisitions of assets. | Check whether an entity acquisition falls within a mandatory notification route. Asset acquisitions are not automatically subject to mandatory notification, though they may be called in and may be voluntarily notified. Assess the rights transferred and seek case-specific advice where appropriate. |
| United Kingdom: Foreign Influence Registration Scheme (FIRS) | Registration requirements for certain arrangements involving activity at the direction of a foreign state or a specified state-controlled organisation. | Check whether the arrangement and activities meet the scheme’s requirements; a foreign grant by itself does not establish that they do. |
UK NSI screening and export-control processes are separate, so one clearance does not necessarily meet the other’s requirements. For a real transaction, the result depends on location, transaction structure, research, entities, award terms, and rights transferred. Obtain advice from the institution and relevant authority rather than inferring a legal conclusion from these general examples.
How should two funding offers be compared?
Compare offers on the same facts and over the same proposed period. A larger cash contribution is not, by itself, a complete measure of either value or risk.
- Resources: cash and in-kind value, duration, conditions, and the people or facilities supplied.
- Source: funder identity, transparency, ownership or control, intermediaries, and relevant affiliations.
- Governance: ability to direct research, choose priorities, participate in oversight, or approve outputs.
- Access: rights to researchers, data, facilities, software, materials, and results.
- Outputs and IP: publication and confidentiality terms, ownership, licensing, exclusivity, and future-output rights.
- Researcher obligations: overlap with other support, effort and time demands, conflicts, and disclosure conditions.
- Compliance and mitigation: sponsor requirements, possible notifications or registrations, export-control questions, and safeguards that would preserve useful collaboration.
Official sources cited here establish no universal numeric risk score or threshold. A documented, fact-specific comparison is more useful than assigning a score that implies false precision.
What context do U.S. federal funding figures provide?
The Government Accountability Office reported a National Science Foundation estimate of about $1.4 billion in federal research-and-development 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 reported that agencies had difficulty determining foreign ownership and matching certain listed entities to funding records; its recommendation for the Office of Science and Technology Policy to facilitate information sharing remained open in March 2026. These system-level challenges provide context for careful records and disclosures, but do not establish that any particular foreign-funded project is improper.
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Who can help with a case-specific review?
Route questions to the institutional offices responsible for the relevant part of the arrangement: research security, sponsored programs, legal counsel, export control, and technology transfer. In the UK, Cabinet Office NSI guidance identifies the Research Collaboration Advice Team as a source of case-specific advice. For U.S. federally supported work, consult the actual agency award conditions and institutional research-security procedures. NIST’s 2025 Safeguarding International Science: Research Security Framework describes an integrated, mission-focused, risk-balanced approach. It also 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.”
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