Foreign Disclosure and Risk Management

Highlights

Learn more about SBIR foreign disclosure requirements and the due diligence program at CDC.

Key Objectives

In the SBIR and STTR Extension Act of 2022, signed into law by President Biden on September 30, 2022, Congress requires Federal agencies to establish a due diligence program to assess security risks posed by applicants.

The SBIR and STTR Extension Act of 2022 includes major changes to the SBIR and STTR programs, including:

  • disclosure requirements regarding ties to foreign countries,
  • a requirement for federal agencies that manage SBIR and STTR programs to establish a due diligence program to assess security risks posed by applicants, and
  • denial of award and recovery authority provisions when ties to foreign countries of concern pose a significant security risk.

Details of the SBIR (and STTR) Foreign Disclosure and Risk Management Pre-award and Post-Award Requirements can be found in NOT-OD-24-029.

Quick Links (to the NIH Foreign Disclosure and Risk Management resources)

Disclosure Requirements Regarding Ties to Foreign Countries

Applicants to the SBIR (and STTR) programs are required to disclose all funded and unfunded relationships with foreign countries, using the Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries Form (hereafter referred to as the SBIR STTR Foreign Disclosure Form), for all owners and covered individuals.

Submission is Required

Applicants should submit the completed SBIR STTR Foreign Disclosure Form during the initial application process.