Prohibition on Malign Foreign Talent Recruitment Program Participation

Long-Standing Requirement Updated for FY 2025

Prior to FY 2025, many DOE funding opportunities included a notice that if applicants were participants in foreign government-sponsored talent recruitment programs sponsored by a country of risk, they were prohibited from participating in projects selected for DOE funding. For FY 2025 funding opportunities and awards, DOE has updated the terminology and requirements in its longstanding prohibition to better align with the OSTP Foreign Talent Recruitment Program Guidelines issued in February 2024.

Requirements for Covered Individuals

At Application:

  • Certify that you are not currently participating in a malign foreign talent recruitment program (MFTRP) 
  • Include your signed certification with your Current and Pending Support disclosure

During Project: 

  • Notify your employer and DOE if there are any changes to your MFTRP participation status

Requirements for Prime Applicants/Recipients and Subrecipients

At Application:

  • Provide the identity of all owners, principal investigators, project managers, and covered individuals who are a party to any Malign Foreign Talent Recruitment Program (MFTRP) 
  • Certify that each covered individual has been made aware of the MFTRP prohibition and complied with the certification requirement via the Current and Pending Support disclosure

During Project:

  • Exercise ongoing due diligence to reasonably ensure that no individuals participating on the DOE-funded project are participating in a MFTRP
  • Notify DOE within five business days upon learning that an individual on the project team is or is believed to be participating in a malign foreign talent recruitment program