IntegrityStar, July 2026 edition
Each edition of the IntegrityStar features an actual investigation conducted by an investigative office at UCF (note, all names have been changed in an effort to provide confidentiality of the parties involved). This edition covers an investigation related to foreign influence and export controls.
Background
A UCF Graduate Research Assistant (GRA) reported to the dean of their college that the GRA’s faculty supervisor was collaborating and sharing group secrets and exhibiting questionable behavior with a university in China. The dean promptly shared the information with the UCF Office of General Counsel and the Office of International Collaboration and Export Control (OICEC). OICEC conducted a foreign influence inquiry and subsequent investigation.
Findings
After conducting the investigation, OICEC did not substantiate the allegations. No information was identified indicating that technology had been unlawfully exported, that the faculty member failed to comply with UCF Policy 4-209 Export Control, or that the faculty member failed to comply with any written procedures related to export control or inappropriate foreign influence. In fact, OICEC identified that the faculty member had a proactive working relationship with OICEC and often reached out with questions related to engaging in activities with entities/individuals in China. With this said, as part of the investigation, OICEC did identify a few foreign influence red flags and provided the below recommendation to both the dean and the faculty member.
Recommendation
Individuals and entities subject to U.S. law are generally prohibited from engaging in most activities with U.S. denied parties. A helpful resource for identifying U.S. denied parties can be accessed on the International Trade Administration Consolidated Screening List. While the faculty member did not engage in activities with a U.S. denied party, OICEC did identify a few publications with entities that would be considered high-risk. OICEC recommended that the faculty member cease all collaborations with high-risk entities and reminded the faculty member that a list of high-risk entities is available on the OICEC website.
It is worth noting that the prompt communication by the college’s dean allowed OICEC to respond to the allegations in an expedited manner and was greatly appreciated. In addition, the proactive working relationship that the faculty member had with OICEC was and continues to be critical in assisting the faculty member in mitigating the risks related to inappropriate foreign influence.