Yesterday, the U.S. Department of Education (ED) and the U.S. Department of State (State) opened foreign funding investigations into Duke University (Duke) and the University of North Dakota (UND) after reviews of university records indicated the submission of incomplete, inaccurate, and untimely disclosures.
Both Duke and UND are research institutions that have received significant taxpayer support for the development of critical and emerging technologies. Pursuant to Section 117 of the Higher Education Act of 1965, postsecondary institutions receiving federal financial assistance must disclose foreign source gifts and contracts with a value of $250,000 or more annually.
These investigations follow yesterday’s House Foreign Affairs Subcommittee hearing that examined the ‘covert malign influence’ operations involving China and Cuba.
“Unfortunately, it appears that both Duke and UND have provided untimely and incomplete foreign funding disclosures, which include erroneously identifying certain governmental partners as ‘non-governmental,'” said Under Secretary of Education Nicholas Kent. “Section 117 requires that institutions of higher education clearly and accurately report their foreign financial ties in a timely manner – to ensure public transparency and as a condition of participating in the federal student aid programs. We expect these universities will cooperate fully. The Department of Education and the Department of State will continue to work together to vigorously ensure the integrity and accountability of our nation’s colleges and universities in reporting their foreign gifts and contracts.”
“Our reviews found real gaps in how Duke and UND have handled their Section 117 obligations – disclosures submitted late, key details left out, and at least one foreign government partner mischaracterized as a non-governmental entity,” said Under Secretary of State for Public Diplomacy Sarah B. Rogers. “The law is clear: colleges and universities must report foreign gifts and contracts accurately and on time. We expect Duke and UND will work with us transparently as this review moves forward. The State Department remains committed to partnering with the Department of Education to hold higher education institutions accountable for full and honest disclosure of their foreign funding.”
Investigation into Duke University’s Foreign Financial Disclosures
In 2013, Duke partnered with China’s Wuhan University (WU) to establish the Duke Kunshan University (DKU) in Kunshan, Jiangsu in (China). WU is overseen by China’s State Administration of Science, Technology and Industry for National Defense (SASTIND), which plays a key role in China’s national defense science and technology innovation system, and “trains [China’s] cyber warfare specialists.”
As described in the NOI, the Chinese government requires joint venture universities, like DKU, to be governed by China’s Ministry of Education and include a “party-run [CCP] unit [to] monitor operations and have a say over big administrative tasks.” Cooperation by the DKU joint institute is mandatory. An examination of DKU’s leadership and governance indicates that it is comprised of prominent Chinese government and Wuhan University officials.
In August 2026, the U.S. Department of War issued a formal notification to Duke University, among other research universities, directing it to initiate immediate and comprehensive reviews of its academic, financial, and research collaborations with foreign entities of concerns.
To verify Duke University’s compliance with the law and the accuracy of its previous disclosures, the agencies’ investigation requires that Duke produce certain records within thirty (30) calendar days, including, but not limited to:
- Various tax records related to Duke’s extensive foreign involvements as provided to the Internal Revenue Service (IRS), U.S. Department of the Treasury (Treasury), and Federal Elections Commission (FEC);
- Verification of the adequacy of institutional controls, documents, and records related to Duke’s Section 117 compliance structure;
- Records related to Duke’s agreements with foreign entities regarding international students, faculty, and research personnel;
- Records related to Duke’s extensive international research collaborations;
- Records related to the participation of Duke personnel in foreign government talent programs; and
- Copies of Duke’s reportable foreign gifts, grants, and contracts.
Investigation into the University of North Dakota’s Foreign Financial Disclosures
UND is a recipient of significant federal awards in support of its School of Aerospace’s “uncrewed air systems” efforts. Those efforts, critical to U.S. national security interests, have also drawn significant investment and involvement to UND by Chinese aviation companies known to have close associations with China’s military.
To verify UND’s compliance with the law and accuracy of its disclosures, the agencies’ investigation requires that it produce certain records within thirty (30) calendar days, including, but not limited to:
- Various tax records related to UND’s foreign involvements as provided to the IRS, Treasury, and FEC;
- Verification of the adequacy of institutional controls, documents, and records related to UND’s Section 117 compliance structure;
- Records related to UND’s agreements with foreign entities regarding international students, faculty, and research personnel;
- Records related to UND’s international research collaborations;
- Records related to the participation of UND personnel in foreign government talent programs; and
- Copies of UND’s reportable foreign gifts, grants, and contracts.
Background
Section 117 of the Higher Education Act of 1965, as amended, mandates that federally funded institutions of higher education disclose any and all foreign gifts at or above $250,000. It is intended to protect national security and academic integrity by curbing undue foreign influence in higher education. Noncompliant institutions risk enforcement by the U.S. Department of Education’s Office of the General Counsel and U.S. Department of Justice, including civil actions to recoup the costs of investigation and enforcement. Noncompliant institutions may also jeopardize their participation in Title IV student aid programs.
On February 23, 2026, ED and State established the Section 117 Partnership to improve the accuracy and transparency of foreign gift and contract reporting for certain domestic public and private institutions of higher education. Through this partnership, State supports ED in managing the Section 117 foreign funding reporting portal and uses its national security and foreign national academic admissions expertise to review and assess the higher education industry’s compliance with the law and America’s national security interests.