There was no such legal requirement on this grant.

>"What tipped the scale, the people said, was an interview by prosecutors this month of a senior Energy Department official who is considered an authority on what disclosures are material on grant forms. The official confirmed that the 2017 form did not require disclosures of Chen’s ties to the technology university or other Chinese government organizations and programs, one person said"

https://www.washingtonpost.com/national-security/mit-gang-ch...