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Division of Risk, Ethics and Compliance

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GA-48 Information and FAQs


Governor Abbott issued Executive Order GA-48 on November 19, 2024, “relating to the hardening of state government.”  Under this order, State agencies and institutions of higher education, including Texas A&M University, are required to implement measures to safeguard employees, critical infrastructure, and sensitive information from access by foreign entities deemed to pose significant risks to the state.

Texas A&M University is committed to upholding the highest standards in all its operations.  In response to Executive Order GA-48, an implementation committee was established on February 20, 2025, and has worked diligently to address the requirements of the order and employee concerns.  This committee is also focused on providing clear and comprehensive guidance to the Texas A&M community that is rooted in our core values of Respect, Excellence, Leadership, Loyalty, Integrity, and Selfless Service.  As Texas A&M moves forward in implementing the various measures, we understand that our community may have specific questions and uncertainties. The following information aims to provide further clarity.


General Information

How does GA-48 impact Texas A&M University?

Executive Order GA-48 mandates that Texas state agencies and higher education institutions, including Texas A&M University, implement measures to protect against foreign adversary influence by placing restrictions on certain activities, such as gifts, professional travel, and participation in foreign recruitment programs. The order also requires the implementation of personal travel notification processes and the establishment of minimum qualifications for critical infrastructure positions. Overviews of the requirements and answers to frequently asked questions are provided on this website.

How does GA-48 define “foreign adversary”?

The foreign adversaries identified in GA-48 are those included on the U.S. Department of Commerce’s foreign adversary list under 15 C.F.R. Section 791.4, which currently includes the following:

    • The People’s Republic of China, including the Hong Kong Special Administrative Region and Macau (China);
    • Republic of Cuba (Cuba);
    • Islamic Republic of Iran (Iran);
    • Democratic People’s Republic of Korea (North Korea);
    • Russian Federation (Russia); and
    • Venezuelan politician Nicolás Maduro (Maduro Regime)
When do these changes go into effect?

Texas A&M must provide certification of compliance with the requirements of GA-48 by August 2, 2025.


Contracts & Procurement

With respect to a contract or bid for goods or services, companies must certify that the company, and any of its holding companies or subsidiaries, is not:

  • Listed in Section 889 of the 2019 National Defense Authorization Act (NDAA).
  • Listed in Section 1260H of the 2021 NDAA.
  • Owned or controlled by the government of a country on the U.S. Department of Commerce’s foreign adversaries list under 15 C.F.R. § 791.4.

Additionally, Texas A&M University cannot enter into a new contract, contract extension, or contract renewal for a good or service with any company that meets the criteria above.

Are there any exceptions to the contract and procurement restrictions?

Yes, if the good or service is necessary to fulfill a core function that directly benefits Texans and can only be provided by an entity that meets the restricted criteria, a contract, renewal, or extension may be allowed for up to one year.

What office(s) should I contact with questions about the contracting and procurement requirements?

Questions regarding the contract process and/or restrictions should be directed to Contract Administration at (979) 845-0099 or [email protected].  Procurement questions should be directed to Procurement Services at (979) 845-4570 or [email protected].


Gifts and Business Travel

Texas A&M employees are prohibited from accepting any gift, regardless of value, from an individual or entity associated with a foreign adversary.  Professional travel to foreign adversary nations is also prohibited.  Texas A&M University must include this in its ethics policies and must provide a mechanism for employees to report being offered such gifts or travel, as well as alleged violations of this directive.

What is considered a “gift”?

A “gift” is anything of value received without providing compensation in return. This could include, but is not limited to, tangible items (e.g. equipment, supplies, materials) and services.

What does “entity associated with” mean?

“Entity associated with” refers to any organization, group, or individual acting on behalf of or closely affiliated with a foreign adversary government. This includes government agents and agencies, state-owned enterprises, research institutes, and other organizations.

What should I do if I am offered or receive a gift by an entity or individual who meets the restricted criteria?

Employees should decline any offers of gifts and/or travel from an individual or entity associated with a foreign adversary and immediately report any offers of gifts or travel from a foreign adversary in Huron.

If an unsolicited gift is sent from an individual or entity representing a foreign entity, the gift should immediately be reported in Huron and to the recipient’s supervisor.  Employees should then consult their supervisors to determine what to do with the gift.

What constitutes “travel for professional purposes”?

“Travel for professional purposes” includes any travel related to an employee’s Texas A&M University responsibilities or in support of the University’s mission and purpose, such as attending conferences, conducting research, presenting at workshops, or engaging in collaborative activities.

I have ongoing collaborations that involve travel to a foreign adversary country. Can I continue this work?

Executive Order GA-48 prohibits travel to a foreign adversary nation as a representative of Texas A&M or for the purposes of conducting Texas A&M University business.  Texas A&M University recognizes international collaborations are vital to the discovery and innovation essential to addressing global challenges.  As such, employees are encouraged to partner with collaborators in ways that uphold our values and are compliant with all applicable requirements, including TAMU System Regulation and TAMU Rule 15.05.04, High Risk Global Engagements and High Risk Global Collaborations.

I am invited to an international conference hosted in a foreign adversary country. Can I attend?

No, Executive Order GA-48 prohibits travel to a foreign adversary nation as a representative of Texas A&M or for the purposes of conducting Texas A&M University business.  Employees are encouraged to identify avenues for professional development and knowledge exchange that align with our institutional values and the requirements of the executive order.

How do I report potential violations of these requirements?

Reports of potential ethics violations can be reported to the Texas A&M System Risk, Fraud & Misconduct hotline at EthicsPoint or (888) 501-3850.

Who should I contact for guidance on these requirements?

Questions regarding the GA-48 gift and travel requirements should be directed to the Division of Risk, Ethics & Compliance at [email protected] or (979) 458-8191.


Personal Travel

Texas A&M University employees are required to submit notification of personal travel to a foreign adversary nation prior to the travel, as well as a post-travel brief.

Does this order restrict personal travel?

No, Texas A&M employees may travel to these countries for personal reasons.  However, the order requires individuals to notify the university before personal travel to a foreign adversary nation and to submit a post-travel brief upon return.

What constitutes “personal travel to a foreign-adversary nation”?

“Personal travel to a foreign-adversary nation” is defined as travel to any of the countries identified in the Executive Order for non-university purposes, such as holidays, vacations, or family visits.

Can I access university resources or work on TAMU tasks while on personal leave in a foreign-adversary nation?

It’s important to keep personal and university activities separate during such trips.  Therefore, employees should not engage in any university business while traveling in foreign-adversary nations, including accessing university systems or meeting with collaborators for work-related purposes.

Additionally, the university network blocks access to campus resources from systems and networks located in foreign-adversary nations.  Employees should not count on being able to connect to university systems from those locations and are encouraged to work with their supervisor to cover work needs while out of the office and to proactively discuss communication plans in case the need arises.

Which employees are required to report personal travel?

All Texas A&M University employees who are active on payroll in Workday, including full-time, part-time, and 9-month appointments with continued service, are required to complete the personal travel notification process.  This includes faculty, staff, and student employees.

How do I submit the required pre-travel notification?

Pre-travel notification is submitted using the Certification of Personal Travel to a Foreign Adversary questionnaire in Workday.  To access this questionnaire:

  • Login to Workday using your university credentials.
  • Search for Create Request in the search bar.
  • In the Request Type box, select Certification of Personal Travel to a Foreign Adversary and select OK.
  • Complete the required information, including your planned travel dates and destination country/countries.
  • Upon submission, your supervisor will be prompted to review and acknowledge the information.

How do I submit the required post-travel briefing?

The post-travel task will appear in your Workday Inbox once your manager acknowledges receipt of the pre-travel submission.  After you return:

  • Navigate to your Inbox and select Request Process: Certification of Personal Travel to a Foreign Adversary.
  • Complete the required information, including your travel dates, destination country/countries, and an overview of the purpose of your travel.
  • Select Submit.
  • Upon submission, supervisors will be prompted to review and acknowledge the information.

Where can I go for detailed instructions on completing the personal travel notification process?

Workday Services created a detailed guide for employees to complete the certification for personal travel to a foreign adversary process.  The guide can be accessed by going to Certification of Personal Travel to a Foreign-Adversary and logging in with your SSO credentials.  Questions or concerns about accessing this process should be directed to [email protected].

What is Texas A&M doing to address concerns about the privacy and confidentiality of the disclosed personal travel information?

This information is collected solely for the purpose of fulfilling the requirements of Executive Order GA-48.  Texas A&M University is committed to protecting the privacy and confidentiality of your personal information.  All submitted travel information will be handled with respect and integrity, and access to this information will be limited to authorized personnel.  All data will be managed in accordance with applicable state and federal laws, including record retention and public information request regulations.


Human Resources and Contractors

Texas A&M is required to establish minimum qualifications for employees with responsibilities related to our critical infrastructure, and to routinely review necessary restrictions to our critical infrastructure by employees and contractors based on criminal history and continuous connections to a foreign adversary.  Additionally, employees are prohibited from taking part in a foreign recruitment program by a foreign adversary nation.

How does GA-48 define “critical infrastructure”?

“Critical infrastructure” is defined in Section 117.001(2), Business Commerce Code as, “a communication infrastructure system, cybersecurity system, electric grid, hazardous waste treatment system, or water treatment facility.”  Further, cybersecurity means, “the measures taken to protect a computer, computer network, computer system, or other technology infrastructure against unauthorized use or access.”

How is Texas A&M identifying employees with responsibilities related to critical infrastructure?

Texas A&M University is currently reviewing position descriptions to identify roles that research, work on, or have access to critical infrastructure.  As these are identified, the following statement will be added to the Job Profile and position restrictions: “Ability to maintain the security or integrity of critical infrastructure, which may include communications systems, computer networks and systems, cybersecurity systems, electrical grid, hazardous waste treatment or water treatment system.”

What is a “foreign recruitment program”?

The CHIPS and Science Act of 2022 generally defines a foreign talent recruitment program as an effort by a foreign government or entity to attract individuals, regardless of their nationality, to contribute to the foreign entity’s advancements.  These programs often offer incentives, including but not limited to cash, in-kind compensation, complimentary travel, special titles, or other forms of remuneration.  GA-48 prohibits Texas A&M University employees from participating in any foreign talent recruitment program by a foreign adversary.

What does “continuous connections to the government or political apparatus of a foreign adversary” mean?

Executive Order GA-48 does not explicitly define “continuous connections.”  For the purposes of reviews related to critical infrastructure and employee attestations, Texas A&M provides the following guidance.  A “connection to a foreign government or political apparatus” is generally understood to encompass:

  • Direct connection.
    • Currently or has been previously employed by, contracted by, or otherwise formally affiliated with a foreign government, a foreign government-owned entity, or a foreign government-controlled organization.
    • Receives or has received financial compensation, benefits, or material support directly from a foreign government or its controlled entities.

  • Immediate Family Connection
    • The individual’s immediate family member — defined as spouse, domestic partner, parent, stepparent, child (biological, adopted, or stepchild), sibling, stepsibling, or any individual with whom the subject shares a close familial bond — is:
      • Currently employed by or contracted to a foreign government or government-controlled entity, or
      • Receiving financial benefits, pension, or material support from a foreign government, or
      • Holding a position of influence, decision-making, or advisory capacity on behalf of a foreign government.

  • Other Relevant Ties
    • The individual or their immediate family holds dual citizenship or permanent residency with obligations (such as military service or government loyalty oaths) to a foreign government that may present a conflict of interest.
    • The individual or their immediate family engages in formal political activity on behalf of a foreign government.

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