Research Security in the Gray: Navigating (and Shortening) the Gap Between Identifying a Risk and Addressing It

As a community, those of us working in research security know what failures look like. A failure is well defined. What is less clear is a consistent answer for what an institution should do when it encounters one, ideally before it becomes another headline.

Over the past two to three years, countless Congressional investigations have highlighted issues that Research Security Officers (RSOs) already know to be significant research security concerns, including foreign affiliations with entities on restricted-party lists, prohibited collaborations with individuals or organizations associated with listed entities, insufficient funding disclosures, and instances in which U.S.-funded research may have benefited “foreign adversaries” advancement of Critical and Emerging Technologies.

More recently, these concerns have moved beyond investigative reports and into institutional consequences, with universities increasingly facing federal funding audits, entity-list compliance reviews, and significant financial penalties tied to undisclosed affiliations and other research security concerns.

But identifying the risk is only part of the challenge. The real difficulty begins when an RSO has to determine what that risk means, how significant it is, and what should happen next.

Research Security in the Gray

This is where Research Security in the Gray exists: in the space between identifying a potential risk and determining what that risk actually means. As federal agencies continue to develop and refine research security requirements, RSOs are increasingly encountering real-world scenarios that do not fit neatly within defined policies, outlined prohibited activities, or simple entity-list matches.

This challenge was a recurring theme at the Georgia Tech Research Collaboration & Safeguards Workshop this month. In discussions with RSOs and federal agency representatives, several questions emerged that illustrate the difficulty – and potential dangers – of the growing gap between identifying a potential risk and determining how to appropriately address it:

• Collaboration vs. Co-Authorship: When does a shared publication represent a meaningful research collaboration? How should an RSO evaluate degrees of separation when a U.S. researcher works with an approved collaborator who separately works with an individual affiliated with a restricted party entity?
• Malign Foreign Talent Recruitment Program (MFTRP) Attribution: How should an institution evaluate potential participation in a MFTRP when there is no comprehensive, continuously maintained list of programs or participants? What evidence is sufficient to move from an indicator to an attribution?
• Indirect Relationships: How should an RSO evaluate an investor, corporate partner, or other organization when an indirect relationship connects it to an entity on a restricted list?
• Emerging Technologies: Where does the use of foreign-developed LLMs and other emerging technologies fit into research security considerations when the technology is being used to support research rather than incorporated into the research itself?
• Mitigation Factors: Once a potential concern is identified, what additional information, contextual factors, or mitigating circumstances should be considered before determining the appropriate institutional level response?

These are the operational gaps created by that research security gray area – where the risk may be identifiable, but the path to a consistent and defensible response is less clear.

Closing these gaps will require more than identifying additional risks. It will require institutions to build the data, context, and decision frameworks necessary to consistently evaluate what those risks mean in order to determine what should and will happen next.

What RSOs Need to Navigate the Gray

Context beyond the initial signal.
A potential risk rarely exists in isolation. RSOs need visibility across people, organizations, affiliations, publications, funding, investments, and other relationships to understand whether a signal represents a meaningful concern or simply a connection that requires additional context.

Evidence that supports the determination.
When attribution is not straightforward, particularly in areas such as MFTRP participation, RSOs need more than a binary result. They need the underlying evidence, source provenance, and supporting indicators necessary to evaluate the strength of an association and document how the determination was reached.

A framework for evaluating relationships.
Co-authorship, collaboration, institutional affiliation, corporate relationships, and other connections cannot always be evaluated equally. Institutions need repeatable ways to assess the nature, duration, proximity, and relevance of those relationships within the context of the research being reviewed.

A consistent path from risk to response.
Identifying a potential risk should be the beginning of an assessment, not the conclusion. RSOs need a structured process for moving from signal → context → evidence → assessment → mitigation, while preserving professional judgment and documenting the rationale behind the final determination.

The objective is not to create policy where policy does not yet exist. It is to give institutions a practical framework for operating within the policy that does exist and for consistently documenting professional judgment where additional guidance is still developing.

For the past several years, the research security ecosystem has worked to identify what can and has gone wrong. Now, the conversation needs to shift toward what happens next and how we give institutions and RSOs the tools to get it right.

Finch AI and our partners will continue these conversations with the research security community at Safeguarding America’s Research: Southeast Defense Innovation Center, October 14–15, 2026. We look forward to continuing the discussion around how institutions can move from identifying research security risks to operationalizing consistent, evidence-based approaches for addressing them.