Compliance & Ethics
The University of Florida’s involvement with foreign entities, including foreign governments, foreign companies, citizens of foreign countries, and agents acting on behalf of any of these entities, is regulated by federal and state laws, regulations, and UF policies. Such oversight is designed to reduce foreign influence on academic freedom and protect national security.
At the state level, much of UF’s engagement with foreign entities is controlled by Florida Board of Governors Regulation 9.012 as well as the Florida Board of Governors Activity with Foreign Countries of Concern Guidance Document for State University System Institutions.
As described below, these laws, regulations, and policies cover a wide range of activities, including:
State law prohibits UF, its employees, and its representatives from requesting or accepting any gifts from: (a) institutions of higher education based in statutorily-defined foreign countries of concern or (b) foreign principals. For UF employees and representatives, these rules apply when they are acting in their official capacity on behalf of UF.
This prohibition against requesting or accepting gifts includes physical objects, loans, rewards, promises of future employment, favors, or services.
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Both state and federal law require institutions of higher education, like UF, to disclose gifts and contracts with a foreign source that meet or exceed a financial threshold.
At the federal level, such transactions are reported to the U.S. Department of Education. The combined financial threshold for gifts or contracts from any foreign source is $250,000.00 in a calendar year (January 1 – December 31).
At the state level, such transactions are reported to the Florida Board of Governors. The combined financial threshold for gifts or contracts from any foreign source is $50,000.00 in a fiscal year (July 1 – June 30).
Reports are submitted to the U.S. Department of Education and the Florida Board of Governors, twice a year, in January and July.
UF Compliance and Ethics oversees UF’s foreign gifts and contracts reporting process. Working with almost 100 UF units, UF Compliance and Ethics collects and collates information about gifts or contracts from foreign sources throughout the enterprise to determine whether, when combined, the reporting thresholds are met. Additional information is available on the UF Compliance and Ethics Foreign Gifts and Contracts webpage.
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Federal
State
State law restricts state universities from engaging in certain activities with foreign countries of concern or foreign principals.
Specifically, state universities cannot participate in agreements or partnerships with colleges or universities based in foreign countries of concern, unless the participation is approved, in advance, by the Florida Board of Governors. This restriction also applies to agreements or partnerships with foreign principals. Prior to approving such agreements or partnerships, the Florida Board of Governors must decide that the relationship is beneficial to the university and its students and that it is not detrimental to the safety and security of the U.S. or its residents.
Florida Board of Governors Activity with Foreign Countries of Concern Guidance Document for State University System Institutions contains examples of activities that require Florida Board of Governors approval as well as a matrix outlining the approval process.
Additionally, state universities must report annually to the Florida Board of Governors all grant programs, agreements, partnerships, and contracts they have with any colleges or universities based in foreign countries of control as well as with any foreign principals. UF Compliance and Ethics oversees this reporting process.
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State law requires UF to perform background screenings on all applicants for research positions (i.e., employees, visiting researchers, or student researchers) in the following categories:
(a) citizens of a foreign country who are not permanent citizens of the U.S. and
(b) U.S. citizens or permanent residents of the U.S. who “have any affiliation with an institution or program, or at least 1 year of prior employment or training, excepting employment or training by an agency of the United States government, in a foreign country of concern.”
The screening must be completed prior to interviewing or offering applicants a position.
UF Human Resources conducts preliminary reviews of finalist for research positions. As UF’s designated Research Integrity Office, UF Research Integrity, Security & Compliance conducts the final review of such applicants and also reviews non-employment requests by departments to host international scholars and visitors.
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State law requires UF to pre-approve and monitor any employment-related foreign travel and foreign activities undertaken by faculty, researchers, and research department staff. As UF’s designated Research Integrity Office pursuant to Florida Board of Governors Regulation 9.012(4), UF Research Integrity Security and Compliance oversees this multi-step process, which is laid out on UF’s Initiating International Business Travel webpage.
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Information is available on UF Research Integrity Security and Compliance’s Export Controls webpage.
Information is available on UF Research Integrity Security and Compliance’s International Engagement and Collaborations webpage.