Transparency of Foreign Connections Disclosure and Certification
FAQs
Answer: Generally, the Transparency of Foreign Connections disclosure is required from the prime applicant and sub awardees – and may be requested of other collaborators during award negotiation if deemed necessary by our research security experts. Unfunded partners typically do not need to provide a Transparency of Foreign Connections disclosure or identify senior/key personnel.
Answer: Each NOFO, RFA, or other funding opportunity will specify in the text of the funding opportunity whether the TFC form is required. It is required for most DOE grant opportunities.
Answer: The Transparency of Foreign Connections should be executed as a statement by the institution, not the PI.
Answer: There is a separate MFTRP attestation for the PI in both the biosketch and Current and Pending Support (CPS) forms. All covered individuals are required to sign and submit both the biosketch and CPS forms. Question #1 in the TFC form is an attestation by the institution that, to the institution’s knowledge, the covered individuals applying to the funding opportunity from the institution are not party to an MFTRP. DOE will retain this representation from the application materials. The institution may retain these records according to the institution’s policies.
Answer: Organizations may simply state in their responses when questions do not apply to them due to their structure. Any exemptions from the Transparency of Foreign Connections form requirement will be noted in the NOFO instructions or TFC template.
Answer: This information is kept close hold in DOE and not shared outside of the foreign risk due diligence process. DOE understands the importance of confidentiality of Applicant and Recipient disclosures, particularly related to the RTES review. Documents related to the RTES review are saved only in Privacy Act approved systems. Results of reviews, including identified risks, are shared only on a need-to-know basis and shared through encrypted emails or through Privacy Act approved systems. Note per issued notice of funding opportunities, “DOE may share information about the risks identified as part of the RTES due diligence review process or monitoring with other Federal agencies (section 4(e) of the Presidential Memorandum on United States Government-Supported Research and Development National Security Policy-33 [NSPM-33]).”
Answer: Yes. If the subrecipient does not want to submit their Transparency of Foreign Connections disclosure via the prime applicant, the subrecipient may send it directly to RTESInfo@hq.doe.gov. However, the prime applicant should note in the proposal that the subrecipient has done so.
Answer: Most companies can provide information on the investors with greater than 1% ownership. Personal details for the sub-1% holders are not generally required, with one exception—if any sub-1% shareholders hold a golden share or similarly privileged type of equity that gives them veto power or greater voting rights than their share of the company would otherwise indicate, please include their information.
Answer: Per the Transparency of Foreign Connections template, recipients and subrecipients are not required to use this specific template to report foreign connections. However, if another format is used, the signatory must include the same substantive information, a signature, date, and any certification statement(s) provided in Section 3 of the document.