MIT instates new review process for ‘elevated-risk’ international proposals

Results of enhanced review include cutting ties with Huawei, ZTE

Vice President for Research Maria Zuber and Associate Provost Richard Lester PhD ’80 released a letter announcing a new review process for “elevated-risk” international proposals. The new process includes potential review by the Senior Risk Group (SRG), a new body whose focus is risk evaluation.

As of now, “elevated-risk” international proposals are all projects that are funded by, involve work in, or collaborate with those in China (including Hong Kong), Russia, and Saudi Arabia, but the list of countries is subject to change. In an interview with The Tech, Zuber said that the process applies to institutional-scale agreements, where several researchers may be involved, but not smaller projects.

As a result of this new review process, MIT has decided it will not accept new engagements or renew existing engagements with Chinese telecom companies Huawei or ZTE “due to federal investigations regarding violations of sanction restrictions,” according to the letter. Existing engagements will be allowed to continue.

Huawei and ZTE have been recently under federal scrutiny over national security concerns. Meng Wanzhou, Huawei’s chief financial officer, was arrested by the U.S. in December for violating sanctions against Iran. The U.S. forced ZTE to stop business in the U.S. between April and July last year after it violated sanctions against Iran and North Korea; it was allowed to resume after paying $1.4 billion in penalties.

MIT currently has fewer than five engagements with Huawei and none with ZTE, according to Zuber. Engagements are generally two to three years long, though some are longer. Zuber said that she has urged Huawei officials to cooperate with U.S. officials and if matters are resolved, MIT would be willing to reevaluate engagements with them.  

“We’re disappointed by MIT’s decision, but we understand the pressure they’re under at the moment,” Huawei said on Thursday.

The first phases of the proposal review process have not changed. First, the International Coordinating Committee (ICC) conducts a compliance review, which involves the evaluation of project areas such as finance, law, tax, export control and operations. Then, the ICC either approves the project or refers it to the associate provost for international activities. Under the recommendation of the associate provost, the project may undergo academic review by the International Advisory Committee (IAC), which evaluates if the proposed engagement “effectively advance[s] MIT’s core academic mission of education, research and service.”

Under the new process, the Associate Provost may additionally refer the project to undergo Project Risk Review by the SRG. The SRG is composed of the associate provost, the vice president for research, and the vice president and general counsel. The SRG will either approve the project with a risk management plan or prevent the project from proceeding.

Throughout the process, “special attention will be paid to risks related to intellectual property, export controls, data security and access, economic competitiveness, national security, and political, civil and human rights,” according to the letter.

China, Russia, and Saudi Arabia are the countries of focus for this new process, since they “represent some risk to the institution and risk to the individuals who are potentially involved in these collaborations,” according to Zuber. She said that while other countries, such as North Korea or Syria, are also risky they are not countries with whom MIT currently collaborates.

Zuber said the process is meant to manage risk and provide “well-grounded processes to let our researchers feel comfortable and provide them some cover in case anything goes wrong” by setting “conditions for which our researchers can interact profitably with other researchers,” rather than prevent research. “No student should feel that there’s any desire to restrict student involvement,” she added.

As such, impacts so far have been “miniscule,” albeit hard to measure, Zuber said. She noted that in the past, risky proposals have also been rejected, and that this new process merely adds an additional layer of scrutiny.

Zuber framed MIT’s decision to instate this new process as “proactive” in responding to federal concerns about problems like intellectual property theft and national security. “No one in the government said that they were threatening to cut our funding,” she said. She stated that maintaining robust processes shows that MIT is “taking care of our institution and our researchers” and is much more preferable than federal intervention, since MIT better understands its own institutions and researchers.

The process was first informally communicated to faculty about a year ago, according to Zuber. The process was finalized after discussions with stakeholders, including all deans, the Office of Communications, the chair of the faculty, and the Office of the General Counsel.

Zuber said that although some faculty are concerned about how long the review progress will take, most of the response has been positive. She said that faculty have been thankful for the new process because “now they understand that the institution is looking even more carefully at our international cooperations to make sure that they are sound.”