Proposed “Uniform Grants Regulation” Raises New Risks for International Programs and Collaborations
A new NPRM from the Office of Management and Budget (OMB) would significantly reshape federal discretionary grantmaking and allow expanded discretion for the administration to affect its priorities throughout the grantmaking lifecycle. Institutions with programs or collaborations involving China or other countries of concern should assess the potential impact of the proposed regulations now. On May 29, 2026, the Office of Management and Budget (OMB) published a notice of
Alan Grose and Tami Hemingway, XL Law Consulting
Jul 174 min read
China Issues New Regulations on Countering Extraterritorial Jurisdiction Measures by Foreign States
On April 13, 2026, the State Council of the PRC published new Regulations to counter foreign sanctions measures it deems to be improper assertions of extraterritorial jurisdiction. The new Regulations could target organizations and individuals who, by virtue of their compliance with foreign sanctions measures, particularly measures that scrutinize the control of Chinese entities, may be accused of implementing such measures. IHEs with research collaborations or academic pro
Alan Grose, XL Law Consulting
Apr 275 min read
The DOJ Sensitive Data Rule: A Race to Compliance Maturity
On October 6, 2025, the final provisions of the DOJ Sensitive Data Rule took effect, completing the framework for the DOJ’s Data Security Program. Institutions engaging in relevant data-sharing activities should move quickly to ensure compliance. On October 6, 2025, the last provisions of 28 C.F.R. Part 202, “ Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons ” (“DOJ Rule”) took effect, completing the regulatory
Alan Grose, XL Law Consulting
Dec 2, 20256 min read
New Executive Order Signals Heightened Section 117 Enforcement Priority
On April 23, 2025, President Trump issued an Executive Order directing the Secretary of Education to step up enforcement of Section 117...
Alan Grose, XL Law Consulting
May 5, 20252 min read
DOJ Publishes Guidance, Announces Additional 90-Days for Good Faith Efforts to Comply with Sensitive Data Rule
On April 11, 2025, the DOJ National Security Division published new guidance regarding the U.S. Sensitive Personal Data and...
Alan Grose and Emma Bahner, XL Law Consulting
Apr 29, 20255 min read
DOJ Issues National Security Regulation to Limit Transfers of Sensitive Data to Countries of Concern
On January 8, 2025, the DOJ issued a new final rule to prohibit or restrict transfers of bulk sensitive personal data and certain U.S....
Alan Grose and Emma Bahner, XL Law Consulting
Mar 13, 202511 min read
NIH Releases Final Policy Guidance on Access to Foreign Subrecipients’ Data
On September 15, 2023, the National Institutes of Health (NIH) issued Final Updated Policy Guidance for Subaward/Consortium Written...
Anne Wilder, Emma Bahner, and Tami Hemingway
Nov 6, 20236 min read
Office of the Director of National Intelligence Releases “Safeguarding Science” Toolkit
On November 15, 2022, the Office of the Director of National Intelligence (ODNI) released a “Safeguarding Science” toolkit to help the...
Anne Wilder, XL Law & Consulting
Nov 22, 20222 min read
White House OSTP Releases Streamlined Research Disclosure Standards
On Aug 31, 2022, the White House published An Update on Research Security: Streamlining Disclosure Standards to Enhance Clarity,...
Jen Yucel, XL Law & Consulting
Sep 7, 20222 min read
