Department of War updates its research security decision matrix

Over the past several years, DoW has made academic research security a paramount priority.  Concerns about malign foreign influence, intellectual property theft, and other forms of exploitation that threaten research integrity have spawned a combination of statutory and policy directives to strengthen disclosure, transparency, and risk assessment mechanisms. DoW has emerged as a leading proponent of pre-award review frameworks to identify and manage risks of inappropriate foreign influence before DoW releases funding to applicant institutions.

DoW’s January “Fundamental Research Security Initiatives and Implementation” Memorandum intensified efforts to safeguard academic research. The Memorandum:

• Prohibited fundamental research assistance awards to Section 1260H entities -- the list of “Chinese Military Companies Operating in the United States” (see our January 2025 advisory here);
• Created a centralized DoW repository for proposal reviews and information sharing to enable visibility across DoW; and
• Introduced the concept of “annual spot checks” for a subset of DoW fundamental research awards to detect vulnerabilities and enforce compliance.

As described below, the 2026 Matrix builds on these efforts.

Core matrix framework remains intact

Like prior year versions of the Matrix, the 2026 Matrix continues to focus on four primary categories of potential risk in research security:

1. Participation in malign foreign talent recruitment programs
2. Current or prior funding from a Foreign Country of Concern (FCOC)¹ or Foreign Entity of Concern²
3. Foreign patent applications; and
4. Affiliations with certain foreign entities.

These categories remain the foundation for DoW’s pre-award risk evaluation.

Expanded “Prohibited Entity Lists”

The 2026 Decision Matrix significantly expands the list of restricted parties considered in DoW’s risk reviews.  The 2025 Matrix had referenced only four lists -- the Department of Commerce’s Entity List, Section 1286 institutions under the FY2019 NDAA, Section 1260H Chinese military companies, and OFAC sanctions lists. The 2026 Matrix compiles a total of 13 federal lists, which together form the universe of “Prohibited Entity Lists.”  The expanded set of lists effectively increases the possibility that DoW-funded researchers may have affiliations or patents that intersect with a prohibited entity and require mitigation.  

DoW makes clear that an institution of higher education may not receive DoW funds to conduct fundamental research in collaboration with, or to use equipment from, any entity named on the expansive “Prohibited Entity Lists”.

Active collaboration on DoW-funded fundamental research with an entity on the Prohibited Entity Lists is prohibited – i.e., DoW will not support such projects.  Furthermore, DoW requires risk mitigation measures where there are indicators that a researcher is affiliated with an entity on the Prohibited Entity Lists or that Covered Individuals (e.g., key personnel) on DoW awards author publications in scientific journals with authors who are affiliated with an entity on the Prohibited Entity Lists. 

Given the volume of international authors in modern scientific publications – some of whom make only minimal contributions to manuscripts – the focus on co-authors is a real challenge for DoW-funded academic institutions.

Affiliations guidance

Importantly, the 2026 Matrix defines “affiliation” as “academic (not including undergraduate or graduate students), professional, or institutional appointments or positions with a foreign government or a foreign government-connected entity, whether full-time, part-time, or voluntary (including adjunct, visiting, post-doctoral appointment, or honorary).”  The definition is designed to broadly capture professional connections to a Prohibited Entity List organization.  Such affiliations are flagged as risk indicators that trigger mitigation measures or funding restrictions. Already, DoW has communicated with applicant institutions to request an explanation of such affiliations and to require a series of risk mitigation measures relative to relationships with co-authors based at Prohibited Entity List organizations.

Look-back period

The 2026 Matrix now applies a look-back period of five years to evaluate risk, as opposed to ten years under the 2025 Matrix. Recent engagements carry greater significance, while older activities are less likely to trigger mitigation, although they remain part of the overall risk assessment. 

Accordingly, DoW requires mitigation measures where, in the past five years, it finds indicators of a Covered Individual’s participation in a malign foreign talent recruitment program (MFTRP) or of a Covered Individual’s co-authors on scientific publications who are participants in a MFTRP.  (A Covered Individual’s active participation in a MFTRP always is prohibited.)

Similarly, mitigation measures are required where a Covered Individual received funding from a FCOC or Foreign Entity of Concern within the past five years.

Further, DoW requires mitigation measures where, again, within the past five years, a researcher’s patent application that resulted from U.S. government-funded research was filed in a FCOC or on behalf of a FCOC-connected entity, prior to filing in the U.S., or where there is evidence of a patent or co-patent application with an individual affiliated with Prohibited Entity List organization.

Looking ahead

DoW’s 2026 Matrix received praise from Chairman John Moolenaar of the House Select Committee on the Chinese Communist Party.  The House Select Committee has applied significant pressure on federal agencies to prevent U.S. taxpayer dollars from funding research collaborations with restricted Chinese parties.  

As DoW research proposals are increasingly subject to risk mitigation measures as a condition of award, pressure is mounting on institutions to respond to DoW inquiries and to track compliance with risk mitigation plans.  Institutions have adopted several strategies to anticipate DoW’s concerns, promptly address researcher affiliations with Prohibited Entity List organizations, tailor risk mitigation techniques for each project, and document compliance.  Such institutional protocols are critical as DoW doubles down on policies to combat inappropriate foreign influence in Federally funded scientific research.

Authored by Bill Ferreira, Lauren Colantonio, Stephen Propst, Beth Peters, and Zach Sanfilippo..