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Start with what makes this AI project sensitive
Do not treat every AI project—or every international collaboration—as equally risky. Begin by mapping the work and its likely outcomes. NIST’s revised framework, NIST IR 8484r1 (November 2025), recommends grounding risk-benefit decisions in an understanding of the science and its potential outcomes. It adds a Research Security Risk Determination Matrix to support project-specific review. NIST’s framework overview and the revised report are the current references; the 2023 original has been superseded for current framework detail.
For an AI project, make an inventory of the assets and relationships that could be exposed:
- Research materials: datasets, labels, source code, model weights, checkpoints, training recipes, evaluation results, and unpublished findings.
- Infrastructure: compute environments, storage, software, equipment, accounts, and the people or organizations with access.
- Project context: funding, collaborators, affiliations, equipment or services received, planned travel, expected outputs, and any contractual or publication commitments.
Then ask what could happen if each asset were obtained early, altered, or used for a different purpose. Consider whether the work involves a critical or emerging technology, whether it could have dual-use applications, and what needs protection until publication or another authorized release. A model or dataset is not automatically sensitive because it uses AI; the project’s content, potential applications, access, and consequences matter.
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Build safeguards around the project, not a single product
Cybersecurity is one part of an integrated research-security program. Define who is authorized to access research data, software, equipment, and systems, and document how access and transfers are handled. Apply the institution’s security controls to the relevant research environment, with controls proportionate to the information and risks identified in the assessment. The cited guidance supports cybersecurity as a program element; it does not prescribe a particular product, configuration, or AI-specific technical control. A standalone consumer security device is not a substitute for institutional governance and security practices.
Use the following workstreams to turn the assessment into decisions and records:
| Workstream | Review | Document |
|---|---|---|
| People and affiliations | Project roles, relevant affiliations and funding, and the access each role needs. | Access decisions and the rationale for them. |
| Travel and visits | International meetings, conferences, visits, and assistance in kind, including whether project information or equipment may be exposed. | Applicable approvals, guidance given, and any project-specific restrictions. |
| Collaborations | Participant organizations, technology, funding, mission benefit, potential applications, access, and publication plans. | Review outcome, agreement terms, and any required technology control plan. |
| Requests and transfers | Requests for products, services, software, access, or other support, including potential technology-transfer, export-control, or sanctions issues. | Who assessed the request, what rules applied, and the decision. |
NIST’s framework organizes review across researchers, international travel, international collaborations, foreign requests for products, services, or software, and funding opportunities. It recommends weighing the type of collaboration, participant organizations, technology, funding, benefits to the institution, possible military-civil applications, technology-control needs, and publication plans. Where appropriate, a technology control plan can address the data, equipment, software, permitted access, and relevant U.S. export-control requirements. NIST IR 8484r1 provides the framework and checklists.
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Vet collaborations and unusual requests in context
Review the structure and terms of an engagement before granting access or committing resources. Establish who will participate, what each person or organization will contribute, how funding and affiliations are disclosed, what information or systems will be accessible, who may use resulting intellectual property, and what publication expectations apply. Compare those terms with the project’s mission, potential benefits, sensitivity, and applicable institutional and funder rules.
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Apply the same documented criteria consistently regardless of a researcher’s ethnicity or national origin. Review relevant conduct, project context, disclosures, access, and agreement terms. NIST describes its approach as scalable and non-intrusive, designed to protect individual privacy and civil liberties while enabling collaboration. As NIST puts it, “The purpose of research security is not to stifle collaborative research, but rather to enable and safeguard it.”
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Check which U.S. funding requirements apply
Requirements depend on the institution’s funding, the proposal or award, and current agency instructions. Do not assume that every university, project, or researcher has the same obligations. NIST’s current FAQ says institutions receiving more than $50 million per year in federal R&D funding must establish research-security programs addressing cybersecurity, foreign travel security, and research-security training, as well as export control and compliance where appropriate. Agencies may set additional requirements. Confirm the current terms that apply to your institution and awards through the NIST research-security FAQ.
For NSF, the applicable proposal, award date, institutional role, and current instructions determine which IN-149 certifications and reporting rules apply. NSF’s IN-149 implementation FAQ describes, among other provisions:
- Senior/key personnel certification that required research-security training was completed within the 12 months before proposal submission, and an organizational certification of completion.
- A higher-education institution certification that it has an updated responsible and ethical conduct of research plan covering mentorship, research-security threat awareness, export control, disclosure, and reporting.
- Certifications concerning malign foreign talent recruitment programs and, absent a waiver, an agreement with a Confucius Institute.
- Annual reporting of covered foreign financial support of $50,000 or more per source associated with a country of concern.
NSF says it and five other agencies recognize the SECURE Center condensed module and annual refresher module as satisfying their respective training requirements. NSF also offers four expanded online modules, each about 60 minutes. Because training recognition and requirements are agency-specific, check the current NSF Research Security Training page before relying on a course for a particular submission.
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Disclosure matters alongside training. NSF identifies deliberate omissions of appointments, affiliations, and current and pending support as concerns when assessing conflicts and foreign interference. Institutions should make the applicable disclosure process clear to researchers and review submissions under current sponsor instructions; the NSF Research Security page provides agency context.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Make reporting and escalation straightforward
Researchers should know where to take a concern before one arises. Publish a clear institutional route for reporting suspicious requests, unexplained access attempts, disclosure concerns, possible loss of research information, or other security incidents. The route should connect researchers to the offices responsible for research security, cybersecurity incident response, export controls, sponsored programs, and legal or compliance review as appropriate.
NCSC recommends securing institutional environments and partnerships, complying with export-control, disclosure, and funding rules, and promoting training and awareness. Its guide directs institutions to report foreign threat actors targeting them to the FBI or a local FBI field office. If a cleared academic institution suspects targeting, it says to report immediately to its local DCSA counterintelligence agent. Follow institutional incident-response procedures as well. These reporting routes are U.S.-specific; institutions elsewhere should use the competent authorities and rules in their jurisdiction. NCSC’s guide sets out these recommendations.
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Use threat information without overstating it
NCSC’s guide identifies possible targeting sources including foreign intelligence entities, foreign research organizations, competitors and state-backed companies, and disgruntled or opportunistic insiders. It offers brief examples involving an approach by a Chinese government-backed center to a U.S. researcher and universities fined for failing to disclose certain researchers’ foreign affiliations while receiving NASA and NSF funding. The one-page guide does not provide detailed case records or prevalence estimates, so these examples cannot establish how common AI-research espionage is.
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The available official guidance supports applying general research-security practices to AI projects, but it does not establish AI-specific espionage statistics or a bespoke AI security standard. Universities should therefore base decisions on project-specific risks and applicable rules, not a generalized assumption that AI research or international collaboration is inherently suspect.
Keep the program current and proportionate
Assign responsibility for reviewing policies when agency terms or institutional circumstances change, and make sure the people who approve collaborations, access, travel, and funding can consult one another. Record the risk considered, the mission benefit, applicable requirements, the controls selected, and who approved the decision. That record makes it possible to explain why a control is needed, revisit it when a project changes, and protect legitimate open research while addressing identifiable risks.
NIST’s framework is designed to support international collaboration while safeguarding intellectual property, privacy, civil liberties, and the integrity of open science. Its governing principle is practical: “Research security should be positive and supportive, not punitive.” For U.S. institutions, use the current NIST framework, agency award terms, and applicable law as the basis for decisions; this article is not legal advice.
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