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  • Date:

    Department of Education Releases Latest Foreign Funding Disclosures (Feb. 11, 2026)

    The Department of Education released new data on its updated foreign gift reporting portal. For 2025, universities reported more than 8,300 foreign gifts and contracts totaling more than $5.2 billion. The disclosures identify Qatar (over $1.1 billion), the United Kingdom (over $633 million), China (over $528 million), Switzerland (over $451 million), Japan (over $374 million), Germany (over $292 million), and Saudi Arabia (over $285 million) as the largest foreign sources of reportable gifts and contracts to American universities. The Department’s new portal is designed to make information more readily accessible to the public and provides aggregate foreign funding totals dating back to 1986, although these totals are not disaggregated by year.

    Topics:

    Endowments & Gifts | International Ventures | Research | Taxes & Finances

  • Date:

    Department of Education Safeguarding Academia (Aug. 25, 2025)

    The Department of Education (the Department), alongside the Office of the Director of National Intelligence and other federal partners, issued new guidance in its Safeguarding Academia bulletin to alert U.S. colleges and universities to increasing foreign threats to fundamental research, intellectual property, critical technologies, and the U.S. research ecosystem. The guidance also arms institutions with mitigation strategies. The bulletin and reference guides review best practices for recruitment programs, overseas research collaborations, espionage activities of foreign intelligence services, and cyber intrusion. 

    Topics:

    International Ventures | Research | Research Safety & Protection

  • Date:

    Department of Education Foreign Funding Investigation into the University of Michigan (Jul. 15, 2025)

    The U.S. Department of Education (the Department) announced that it has opened an investigation into the University of Michigan following a review of the University’s reports pursuant to Section 117 of the Higher Education Act of 1965 (20 U.S.C. §1011f), alleging inaccurate and incomplete disclosures. The Department, requested that the University provide with tax records, a written narrative of the University’s procedures related to compliance with Section 117’s foreign funding disclosure requirements, a copy of each written agreement with a foreign government, foreign educational institution, foreign non-government entity, or foreign corporate entity relating to international student admissions, detailing the participation of non-U.S. individual or entities in university or university-affiliated research collaborations, identification of all university personnel and contract personnel involved in the university’s assistance and/or efforts related to F-1 Student Visa, work permits, and travel for international students, faculty, and other personnel, identification of all involved in bilateral or multilateral research collaborations with non-U.S. research institutions, identification of all university personnel responsible for the oversight and/or administration of the university’s compliance with federal Foreign Government Talent Recruitment Program restrictions, and, all foreign gifts, grants, and contracts between the University and any foreign source. The time frame for these requests is from January 1, 2020, through the present.  

    Topics:

    Contracts | Employment of Foreign Nationals | Endowments & Gifts | External Investigations | Faculty & Staff | Grants, Contracts, & Sponsored Research | Immigration | International Students | International Ventures | Investigations | Research | Taxes & Finances

  • Date:

    U.S. Department of Homeland Security Notice of Intent to Withdraw at Harvard University (May 28, 2025)

    U.S. Department of Homeland Security (the Department) sent Harvard University a Notice of Intent to Withdraw terminating Harvard’s Student and Exchange Visitor Program (SEVP) certification based on an alleged failure to comply with federal regulations. The Notice states that potential compliance issues were identified during a review of University records, including: (1) failure to comply with reporting requirements; (2) failure to maintain a campus environment free from violence and antisemitism; and (3) practices with foreign entities raising national security concerns. It gives Harvard 30 calendar days to respond regarding the alleged deficiencies and demonstrate compliance with applicable requirements.

    Topics:

    Discrimination, Accommodation, & Diversity | Enforcement of Non-Discrimination Laws | Immigration | International Students | International Ventures | Research

  • Date:

    U.S. Department of Education Updated Foreign Gift and Contract Data (May 9, 2025)

    U.S. Department of Education’s Office of Federal Student Aid (the Department) posted updated information about foreign gifts and contracts reported by institutions of higher education (IHEs) as of February 28, 2025. The data shows more than 529 additional foreign gift and contract transactions valued at approximately $290 million since the Department’s last data release from the July 31, 2024, reporting period. The post states that over 269 IHEs self-reported transactions greater than 131 countries, noting the IHEs reporting the largest total dollar amounts included Harvard University, Stanford University, University of California, Berkeley, University of California, Los Angeles, and Yale University. The Department reported that the largest dollar amounts were sourced from Canada, Hong Kong, Japan, Norway, and Saudi Arabia.  

    Topics:

    Contracts | Endowments & Gifts | Grants, Contracts, & Sponsored Research | International Ventures | Research | Taxes & Finances

  • Date:

    U.S. Department of Education Office for Civil Rights Title IX Investigation into Western California University (May 8, 2025)

    U.S. Department of Education’s Office for Civil Rights (OCR) announced the commencement of a Title IX investigation into Western California University based on allegations that the University refused to comply with Title IX and “ensure sex-separated intimate spaces in federally funded institutions of higher education.” OCR states that it received credible reports that the University did not make changes based on President Trump’s Executive Order and “allowed a male to room with a female in a girls’ dormitory” and that the University “opened an investigation against a female student asking for a male student to leave a female locker room.”  

    Topics:

    Endowments & Gifts | International Ventures | Research | Taxes & Finances

  • Date:

    U.S. Department of Education Opens Foreign Funding Investigation into University of Pennsylvania (May 8, 2025)

    U.S. Department of Education (the Department) announced a foreign funding investigation into the University of Pennsylvania after a review of the university’s foreign reports revealed allegedly “inaccurate” and “incomplete” disclosures. Specifically, the Department asserts that the University failed to disclose any foreign funding prior to February of 2019. To ensure compliance with Section 117, the Department requested that the University produce (1) tax records from January 1, 2017, through present; (2) University systems and written procedures; (3) a copy of each written agreement with a foreign government, foreign educational institution, foreign non-governmental entity, or foreign corporate entity detailing admissions agreements for international students, faculty, scholars, and any research personnel; (4) identification of all personnel involved in research collaborations with non-U.S. research institutions, who oversee the University’s compliance with federal Foreign Government Talent Recruitment Program requirements; and (5) a complete list of all foreign gifts, grants, contracts, and/or restricted or conditional gifts, grants, or contracts between the University and any foreign source.

    Topics:

    Endowments & Gifts | International Ventures | Research | Taxes & Finances

  • Date:

    ACE Letter Opposing the DHS Restrictions on Confucius Institutes and Chinese Entities of Concern Act (May 7, 2025)

    The American Council on Education (ACE) sent a letter to the U.S. House of Representatives expressing opposition to H.R.881, the “DHS Restrictions on Confucius Institutes and Chinese Entities of Concern Act.” The letter states that the proposed legislation would prohibit any Department of Homeland Security (DHS) funding from being awarded to U.S. postsecondary institutions with any type of working relationship with the majority of Chinese colleges or universities. Additionally, it states that the legislation is duplicative of multiple existing laws and agency regulations and would cause compliance confusion as its definition does not align with those used by other agencies and established government policies. The letter goes on to express concern about restrictions on FEMA funds, which institutions rely on to respond to natural disasters, and the new category of “Chinese Entities of Concern.” The letter also states that this new category, as it is so broadly defined, would likely include the majority of Chinese colleges and universities, potentially ending student exchange programs between the U.S. and Chinese institutions, study abroad programs for U.S. students in China, and important research and development work on issues of national importance–all of which are already in compliance with existing research security provisions created to protect U.S. research.  

    Topics:

    Contracts | Grants, Contracts, & Sponsored Research | International Ventures | Research

  • Date:

    U.S. Department of Education Issues Records Request to Harvard University (Apr. 17, 2025)

    The U.S. Department of Education (the Department) sent a records request to Harvard University following a review of the University’s foreign reports, that revealed allegedly incomplete and inaccurate disclosures. To verify compliance, the University must produce within thirty calendar days: (1) a complete and accurate copy of its procedures to achieve compliance with Section 117; (2) a list of all foreign gifts, grants, and contracts from or with foreign sources; (3) the identities of all known parties involved in each of the University’s foreign source gifts; (4) all records regarding or referencing gifts or contracts between the University and foreign governments, without limitation; (5) all records relating to expelled foreign students or foreign students who have had their University credentials canceled from January 1, 2016, through the present; (6) a list of any electronic mail usernames known by Harvard or its personnel to have been utilized by such foreign students; (7) a list of all University personnel with responsibilities relating to the facilitation of the expulsion of foreign students or foreign students who have had their University credentials canceled from January 1, 2016, through the present; (8) a list identifying all full or partial funding sources and amounts for any research conducted by foreign expelled students; and (9) a list of all visiting or temporary researchers, scholars, students, and faculty at the University who are from or affiliated with foreign governments.  

    Topics:

    Contracts | Employment of Foreign Nationals | Endowments & Gifts | Faculty & Staff | Grants, Contracts, & Sponsored Research | Immigration | International Students | International Ventures | Research | Taxes & Finances

  • Date:

    Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security – The White House (Feb. 10, 2025)

    Executive Order: Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security. This Executive Order requires the Attorney General to review guidelines and policies governing investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA); cease initiation of any new FCPA investigations or enforcement actions; review in detail all existing FCPA investigations or enforcement actions and take appropriate action; and issue updated guidelines or policies to adequately promote the President’s Article II authority to conduct foreign affairs and prioritize American interests. 

    Topics:

    Foreign Corrupt Practices Act (FCPA) | International Activities | International Ventures | Research

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