NASA Compliance Updates
Since enactment of the Wolf Amendment in 2011 (Pub. L. No. 112‑10), Congress has prohibited NASA from funding any activity involving bilateral participation, collaboration, or coordination with the government of China or any Chinese‑owned company or entity, regardless of whether funds are exchanged. NASA reaffirmed this restriction in January 2026 in the Consolidated Appropriations Act, 2026 (§ 526, P.L. 119‑74), following congressional inquiries into potential noncompliance and undisclosed ties between U.S. researchers and Chinese institutions.
NASA’s Grant and Cooperative Agreement Manual (GCAM), effective March 21, 2025, reinforces this prohibition and applies it to all NASA grants and cooperative agreements, including at both the prime and subrecipient levels (see GCAM § 9.4 and Appendix A). For purposes of this restriction, “China or Chinese‑owned company” includes the People’s Republic of China (PRC), PRC‑owned entities, and entities incorporated under PRC law, including Chinese universities. The PRC definition includes Hong Kong and Macau, but excludes Taiwan.
This restriction may affect Northwestern researchers who receive NASA funds in the following ways:
- If you have a NASA award: Do not engage in bilateral coordination, collaboration or participation with China or any Chinese-owned companies or Chinese universities, including individuals working for such entities, regarding your award. This restriction includes directly sharing NASA-funded research data through any means, including IT systems, as well as bilateral joint publications with authors affiliated with the Chinese government, Chinese companies, or Chinese universities.
- Publications that include authors from only the U.S. and China are considered “bilateral activities” and are prohibited. Publications that include authors from other countries in addition to the U.S. and China are generally considered to be multilateral activities; thus, NASA funds may be used.
- No NASA grant funds may be spent on any part of a bilateral project with China, even if no funds are sent to China or to a Chinese-owned company.
- Individuals who hold affiliations with Chinese institutions are prohibited from participating in NASA-funded activities. This includes faculty, students, or researchers affiliated with Chinese institutions that are visiting the University, regardless of nationality.
- NASA-sponsored researchers are not allowed to enter into any agreement with Chinese organizations to obtain access to data. However, researchers may use data sourced from China that is publicly available.
Note: These laws do not restrict individual involvement based on citizenship or nationality. University students, postdoctoral fellows, researchers or faculty that are Chinese citizens may work on NASA projects as long as they are not also affiliated with a Chinese institution.
FAQs
What is “bilateral participation” in this context?
A bilateral agreement or collaboration in this case would be a collaboration between a Northwestern researcher and someone affiliated with Chinese institutions or Chinese-owned companies incorporated under the laws of China, rather than an individual of Chinese citizenship or nationality. For example, a Northwestern researcher who is a Chinese citizen may work on a NASA project, but an individual affiliated with a Chinese institution, even if the person is an American citizen, would be subject to the restriction.
As another example, a Chinese postdoctoral associate or other type of researcher at a U.S. university on a visa who is also a faculty/researcher at a Chinese university may not be funded in whole or in part using NASA funds and is not permitted to work on NASA funded projects.
What is a multilateral activity?
In this context, a multilateral collaboration (an agreement/collaboration between three or more parties) would be one that involves researchers in other countries in addition to those affiliated with Chinese entities, or work done through or for a multilateral organization. For example, a NASA-funded investigator using publicly available data that originated in China, or that is accessed on a publicly-available Chinese website, would be permitted. Publications that involve authors from the PRC, USA and other countries are generally considered to be multilateral activities.
Does this restriction apply to vendor agreements?
Agreements for the purchase of non-commercial items of supply from China needed to perform a grant or cooperative agreement are excluded from this restriction. Additionally, agreements for commercial or non-developmental items (as defined by FAR 2.101) needed to perform contracts/subcontracts are exempt from this restriction. Therefore, vendor (i.e. procurement) agreements with PRC entities for commercial or non-developmental items are not subject to this restriction.
Are students and postdocs who are Chinese citizens prohibited from working on NASA-funded projects?
No, as long as they are not also affiliated with a Chinese university or institution. The prohibition does not restrict individual involvement based on citizenship or nationality. For example, a Chinese graduate student enrolled at Northwestern on a visa can work on NASA-funded projects. Conversely, a US citizen who holds a faculty position at a Chinese university would have the kind of affiliation that would bar their inclusion on a NASA-funded project.
Are visiting scholars/researchers who are Chinese citizens prohibited from working on NASA-funded projects?
This will depend on what institution the student/researcher is coming from and how they are funded. If the visiting scholar/researcher is coming from a non-Chinese institution, they would likely be permitted to work on a NASA-funded project. If they are coming from a Chinese institution, they likely would not be permitted to work on a NASA-funded project.
What if I currently have a Chinese national working on my NASA-funded project?
If a research project continues to involve persons affiliated with China or a Chinese entity, NASA will not provide incremental funds. If affiliations with China or Chinese entities have ceased and there will be no further affiliation with China or a Chinese entity related to the NASA-funded activity, you should indicate to the contracting officer that this is the case so that funding may continue.
If this has been going on since 2011, why is this newsworthy?
Congressional leaders have intensified oversight of federal programs amid concerns over compliance with the Wolf Amendment restrictions. In a February 19, 2026 press release, House Select Committee on China Chair John Moolenaar and Senate Judiciary Committee Chair Chuck Grassley announced letters to NASA and the FBI raising concerns about taxpayer-funded research with potential ties to the Chinese Communist Party (CCP).
In their letter to NASA Administrator Jared Isaacman, the Chairs cite prior findings on Department of Energy–funded research involving the People’s Republic of China, alleging that some U.S. researchers maintained ties to Chinese institutions while working on federally funded projects. The letter questions NASA’s compliance with the Wolf Amendment and requests information on agency policies, monitoring processes, and research award and subaward data from fiscal years 2015–2026. In a corresponding letter to FBI Director Kash Patel, Moolenaar and Grassley requested information on Wolf Amendment waiver requests, related investigations since 2015, and interagency coordination on potential violations.
NASA has also published their own FAQs regarding PRC restrictions and the ROSES process.
If you have any questions about these restrictions or about NASA projects, please reach out to the ECIC team at exportcontrols@northwestern.edu.
Visit our Export Controls website for more information about NASA and Export Controls.