The Pentagon’s 30-university audit did not create this problem. Congress wrote the disclosure law in 1986. Federal oversight repeatedly failed. Harvard’s intermediary now provides a concrete test of whether the government can finally see through institutional structure and follow foreign research money to its actual beneficiary.
James Lyons-Weiler, PhD
Popular Rationalism
August 18, 2026
On August 17, 2026, the U.S. Department of War ordered 30 American academic institutions to conduct immediate audits of their academic, financial, and research relationships with foreign entities the government considers security risks. The reviews must examine collaborations involving institutions on the Department’s Section 1286 list and organizations associated with rebranded Confucius Institutes. Universities were directed to determine whether sensitive or export-controlled research has been exposed, mitigate identified risks, terminate problematic relationships where necessary, and report their findings by August 31 if they wish to maintain eligibility for future federal research funding.
The Department’s public announcement does not identify the 30 institutions. A U.S. official provided the list to DefenseScoop, however, and subsequent reporting identifies Harvard, MIT, Duke, Georgetown, NYU, Johns Hopkins and other major research universities among those notified. Harvard therefore appears on the audit list according to reporting based on a government source, rather than from a publicly released Department list. That distinction should be preserved.
Four days earlier, two House committees had released a 53-page investigation of Harvard titled Compromised Independence: CCP Influence at Harvard University. Among its findings was an allegation that deserves considerably more attention than the generalized accusation that Harvard has “ties to China.” The committees identified a Harvard-affiliated nonprofit, Harvard Global Research & Support Services, Inc., through which foreign-sponsored research can be formally awarded even while Harvard University personnel and resources conduct the work. The committees allege that the arrangement “appears to be designed to circumvent” federal foreign-funding disclosure requirements.
That allegation has not yet been proved. The structure, however, is real.
And after forty years of sporadic enforcement of a federal foreign-funding disclosure law, the structure gives investigators a remarkably clean question to answer.
The Question Is Whether the Money Remained Reportable
Section 117 of the Higher Education Act is fundamentally a transparency statute. An institution receiving federal financial assistance generally must report gifts from and contracts with a foreign source when the value reaches $250,000 in a calendar year, whether through one transaction or aggregated transactions with the same source. The law does not prohibit universities from taking foreign money. It requires qualifying foreign money to be disclosed.
That distinction matters because the Harvard Global question is not resolved merely by showing that Harvard created a separate nonprofit.
Harvard Global’s own current website says that, depending on sponsor requirements, Harvard University may ask Harvard Global to serve as the proposal applicant and awardee. Harvard Global then formally accepts the sponsored funding, while “Harvard University researchers perform all research activities using University resources” under contract to Harvard Global. The organization describes its status as “separate-but-affiliated” and says that this allows it to support sponsored activities that Harvard University cannot support because of sponsor requirements or legal limitations overseas.
Harvard Global also says that all projects proposed through and awarded to it are recorded in Harvard’s Grants Management Application System, that University Office for Sponsored Programs personnel also hold appointments with Harvard Global, and that Harvard schools and departments retain responsibilities for approvals, research oversight, facilities and other support. U.S.-based Harvard researchers working on these awards remain on the Harvard University payroll. Harvard Global expressly says that U.S. federal sponsored awards do not flow through its entities.
Those facts are relevant counterevidence to any claim that Harvard Global necessarily operates as a secret off-the-books organization. Its current public description portrays an integrated and internally recorded sponsored-research mechanism.
But internal visibility is not the same question as federal disclosure.
The House committees reproduced Harvard Global’s 2011 IRS Form 990, which stated that the organization would “seek research grants from foreign grantmakers” and would then use those funds to pay Harvard faculty, students and others to perform the research. The committees also reproduced an earlier version of Harvard Global’s website saying that when Harvard University could not accept a sponsor’s terms for legal or financial reasons, Harvard Global could act as applicant and awardee while Harvard researchers performed the work using University resources.
The exact wording highlighted by the committees has since changed. The functional arrangement has not disappeared from the current site. Harvard Global still says it may formally receive an award while Harvard researchers conduct the research using University resources, and that its separate legal status permits sponsored activities Harvard University itself cannot support under certain sponsor or overseas legal requirements.
That is precisely where Section 117 becomes relevant.
The Department of Education’s November 2023 Section 117 guidance specifically addresses intermediaries. Education states that a university receiving the benefit of a foreign gift or contract may still have to report it when the benefit passes through an intermediary. The Department warns that allowing institutions and foreign sources to avoid reporting merely by inserting another entity into the transaction would defeat the statute. It places the ultimate responsibility for reasonable due diligence on the institution receiving the benefit.
The guidance itself also contains an important legal restraint: Education expressly says its FAQ does not create new law and that intermediary questions require individualized, fact-specific assessment.
So the evidentiary burden is straightforward.
For each qualifying foreign-origin award received through Harvard Global, identify the ultimate source, value, contractual terms, Harvard personnel and resources benefiting from the award, and the corresponding Section 117 disclosure.
If the transactions appear in the federal reporting record, the circumvention allegation weakens substantially.
If qualifying transactions benefited Harvard but disappeared from federal disclosure because the immediate recipient was Harvard Global rather than Harvard University, investigators will have something much more serious than an unusual organizational chart.
They will have transactions.
Congress Has Been Waiting for This Ledger Since 1986
The foreign-funding problem did not begin with China, Harvard or the Trump administration.
Congress first required American colleges and universities to publicly disclose certain foreign gifts and contracts in 1986. The Department of Education’s 2020 review of the statute’s legislative history says the original concern involved foreign money potentially affecting academic integrity. According to that review, donations from Arab countries associated with Georgetown University’s Center for Contemporary Arab Studies helped motivate the legislation; Japanese corporate relationships with American research institutions were among the other concerns of the period.
This history matters because Section 117 was not written as an anti-China statute. Its underlying principle was broader: when federally supported universities receive substantial financial support from foreign sources, the public should be able to see the relationship.
The enforcement history was much less impressive than the principle.
A bipartisan Senate Permanent Subcommittee on Investigations report in 2019 examined Confucius Institutes operating at American universities. The subcommittee determined that China had provided more than $158 million directly to U.S. schools for Confucius Institutes since 2006. Nearly 70 percent of schools that had received more than $250,000 from Hanban, the Chinese government entity then administering the program, had failed to report that funding properly to the Department of Education. The Senate report also noted that Education had last issued Section 117 guidance in 2004, the same year the first U.S. Confucius Institute opened, and then remained largely silent as the program expanded to more than 100 institutions.
That was an enforcement failure hiding in plain sight.
The federal government then began paying serious attention. Education’s Office of General Counsel initiated a series of Section 117 investigations beginning in 2019. By February 2026, Education reported that American universities had disclosed $67.6 billion in foreign funding since Section 117 was enacted in 1986 and, remarkably, that the majority of that money had been disclosed only since 2019. More than $2 billion in reportable gifts and contracts were filed late during a period in 2025 alone.
A disclosure law can exist for decades while the information system beneath it remains badly incomplete.
The Department of Education’s own inspector general demonstrated how incomplete the enforcement architecture still was as recently as February 2025. The OIG found that Federal Student Aid’s Section 117 oversight consisted largely of reviewing whistleblower tips, Department news releases and media reports and providing technical assistance. FSA had no monitoring plan, policies or procedures for overseeing compliance. The OIG recommended a monitoring system, annual certifications by senior university officials and stronger controls in the reporting portal.
That finding should prevent the current controversy from being reduced to a morality play about one university.
Universities had disclosure obligations. The federal government had enforcement responsibilities. Both matter.
When an oversight system depends heavily on institutions telling the government what the government does not independently know to ask for, sophisticated institutions will inevitably become the stress test. Affiliates, foundations, overseas campuses, research institutes, foreign subsidiaries, subawards, joint programs and intermediary organizations are precisely where a simplistic “Who received the check?” model begins to fail.
Section 117 eventually had to learn to follow the benefit of a transaction rather than merely the name printed beside “payee.”
Foreign Funding Became a Research-Security Problem
Another change occurred during the same period. Federal concern moved beyond the question of who funded the university toward a more difficult question: what research relationships did the funding and affiliations create?
The Charles Lieber case provides one important Harvard example, but it must be described accurately. Lieber, the former chair of Harvard’s Department of Chemistry and Chemical Biology, was convicted in 2021 of making false statements to federal authorities, filing false tax returns and failing to report a foreign bank account in connection with his relationship with Wuhan University of Technology and China’s Thousand Talents Program. His Harvard laboratory had received more than $15 million in NIH and Defense Department research support.
That case is sometimes invoked as though it proved Harvard itself knowingly participated in the arrangement. The Justice Department said the opposite on that particular point: Lieber’s Wuhan affiliation and Thousand Talents participation were “unbeknownst to his employer, Harvard University.”
The distinction is useful. An individual researcher’s concealment cannot simply be transferred into an allegation of institutional intent.
But the case demonstrated why research sponsors could no longer treat undisclosed foreign appointments, laboratories, support and commitments as ordinary bookkeeping mistakes. NIH had already begun addressing foreign-interference concerns by 2018, including undisclosed foreign support and affiliations, intellectual-property risks and breaches of peer-review confidentiality.
Federal policy then became progressively more systematic.
National Security Presidential Memorandum 33, issued in 2021, established a government-wide research-security framework. The CHIPS and Science Act of 2022 added statutory research-security requirements, including provisions concerning malign foreign talent recruitment programs. NSF subsequently implemented certifications and research-security training requirements for senior personnel and institutions.
In 2023, the Defense Department adopted risk-based security reviews for fundamental research selected for funding. The policy requires assessment of potential conflicts of interest and conflicts of commitment arising from foreign influence and allows mitigation when a relationship presents a research-security risk. The policy also makes an important point that should survive the political temperature surrounding this subject: international scientific collaboration is valuable, and risk reviews are supposed to operate without indiscriminately discouraging it.
That is the correct standard.
Foreign collaboration is not evidence of wrongdoing. Chinese co-authorship is not evidence of espionage. Dual-use potential is not proof that technology was transferred unlawfully. A university appearing on a federal audit list is not a finding of guilt.
But those propositions do not eliminate the obligation to examine a collaboration when federal research funding, military-linked institutions, sensitive technologies, undisclosed affiliations or export controls intersect.
The House Harvard report illustrates the difference. Its investigators say they identified more than 140 publications containing both a Harvard-affiliated author and an author affiliated with one of China’s “Seven Sons of National Defense” universities. The committee’s analysis found engineering to be the dominant subject area.
That count establishes co-authorship. It does not by itself establish illicit technology transfer.
The next analysis has to be paper-specific and project-specific. Which collaborations involved U.S. government funding? Which involved institutions subject to federal restrictions at the time the work occurred? What technology, data, equipment or know-how crossed institutional boundaries? What did Harvard’s compliance system review? What did federal sponsors know? Was the work fundamental research intended for open publication, controlled technology subject to restrictions, or something between those categories?
Those questions are much harder than counting publications.
They are also the questions a serious research-security system is supposed to answer.
The Department of War’s Section 1286 program now formally identifies foreign academic and research institutions considered to present elevated risks of misappropriation of U.S.-funded research. Its FY2025 list, released in July 2026, contains 130 institutions in China, Russia and Iran. Less than a month later came the order requiring 30 American institutions to audit their active relationships against that security architecture.
That is a different system from Section 117, but the two systems are beginning to converge.
One follows foreign money. The other follows research exposure. A competent government should be able to connect them.
Harvard’s Disclosure Record Was Already Unresolved
Harvard was already under Section 117 scrutiny before the House released its Harvard Global finding.
Education opened a Section 117 compliance review of Harvard in 2020. That investigation was closed in December 2024 after Harvard entered an attestation and agreement stating, among other things, that it was current in its Section 117 submissions, had written procedures and systems designed to achieve compliance, and had not knowingly or willfully failed to comply.
Four months later, Education opened another review.
On April 18, 2025, the Department announced that its examination of Harvard’s recent disclosures had identified “incomplete and inaccurate disclosures.” The underlying notice referred to noncompliant transaction disclosures, anonymous donors and deficiencies that also appeared in amended reporting covering 2014 through 2019. That investigation was still open when the House committees issued their August 2026 report.
Those findings do not prove the Harvard Global allegation either. They do make it impossible to dismiss the intermediary issue as a purely hypothetical concern.
Education’s February 2026 disclosure release adds scale. It reports that Harvard disclosed more than $610 million from counterparties located in statutory “countries of concern” between 1986 and December 16, 2025, the highest amount among the institutions identified by Education under that particular measure. That figure should not be casually relabeled “Chinese funding”; Education’s category includes multiple countries of concern. The House report separately cites Education data for its own claim concerning Harvard’s China-attributed funding. They are related measures, not interchangeable ones.
This is exactly where careless reporting can ruin a legitimate investigation. A large foreign-funding number does not prove influence. A Chinese coauthor does not prove military transfer. A nonprofit intermediary does not prove evasion.
The case becomes strong by refusing to transfer evidence from one proposition to another.
What is established is that Harvard Global is a separate Harvard-affiliated nonprofit capable of receiving foreign-sponsored awards; Harvard researchers and resources can perform the resulting work; Education says intermediary transactions benefiting a university can remain reportable; Harvard has experienced repeated Section 117 scrutiny; and the current federal investigation has identified problems in Harvard’s disclosure submissions.
What has not yet been publicly established is the transaction-level proposition necessary to prove circumvention: that Harvard Global received qualifying foreign-origin gifts or contracts benefiting Harvard and that Harvard failed to make Section 117 disclosures that the law required.
That ledger is now the evidence that matters.
Audit the Transactions, Not the Narrative
The federal government has spent forty years building toward a remarkably ordinary accounting exercise.
Take every Harvard Global foreign-sponsored award within the relevant period. Identify the true foreign source and any intermediary. Record the amount and date. Identify the Harvard school, principal investigator and personnel performing the work. Identify the University facilities, equipment and administrative resources used. Determine whether the transaction crossed the Section 117 threshold alone or when aggregated with other transactions from the same source. Then locate the disclosure Harvard filed with Education.
For research-security review, extend the same record to foreign collaborators and institutions. Determine whether any collaborator was on the applicable Section 1286, Entity List or other relevant federal restriction list at the time. Determine the source of U.S. government funding, the nature of the research, applicable export-control status and the mitigation or approval record.
This is what an audit is for.
It should also be done across the other 29 institutions. The history makes clear that foreign-funding underreporting and inadequate federal oversight were never exclusively Harvard problems. A 2019 bipartisan Senate investigation found widespread reporting failures involving Confucius Institute funding. Education’s inspector general found an inadequate federal monitoring system in 2025. Education now says that the majority of the $67.6 billion disclosed since the law was enacted in 1986 was reported only after 2019.
Harvard deserves neither immunity because of its prestige nor a presumption of guilt because it is Harvard.
The same evidentiary rule should apply to every institution.
The House committees have produced enough evidence to justify examining Harvard Global closely. Harvard Global’s own documents establish the intermediary mechanism. Education’s own guidance establishes that an intermediary does not necessarily sever the reporting obligation. Harvard’s recent Section 117 history establishes that its disclosure system has already produced findings serious enough for Education to reopen an investigation. The War Department now has an independent research-security reason to examine foreign collaborations at Harvard and dozens of other institutions.
The remaining questions are factual.
Which foreign awards passed through Harvard Global?
Which of those awards conferred a reportable benefit on Harvard University?
Where are those transactions in Harvard’s Section 117 disclosures?
Did Education examine Harvard Global when it closed the first Harvard investigation in December 2024?
Are any Harvard Global transactions among the incomplete or inaccurate disclosures Education identified four months later?
For the Harvard collaborations involving military-linked Chinese universities, which projects actually involved federal funding, controlled technology, restricted entities or other specific research-security risks?
Those questions can be answered with records.
If the records reconcile, investigators should say so.
If they do not, the government should identify the missing transactions, the responsible reporting entity, the applicable legal requirement and the consequence of the omission.
After forty years, another argument about whether American universities have “foreign ties” would tell us very little.
The government finally has the tools to ask the narrower and more useful question:
What happened to the money and the research after they crossed the institutional boundary?
That is where the record begins.
Source Notes
U.S. Department of War (2026). “Department of War Orders Research Security Audits at 30 Academic Institutions,” August 17, 2026. The order requires the notified institutions to review academic, financial and research collaborations involving Section 1286 entities and organizations associated with rebranded Confucius Institutes and report by August 31.
U.S. House Committee on Education and the Workforce and House Select Committee on the Chinese Communist Party (2026). Compromised Independence: CCP Influence at Harvard University, August 13, 2026. The report contains the Harvard Global finding, reproduces prior Harvard Global website language and the nonprofit’s early Form 990, discusses Harvard’s Section 117 history, and reports the committees’ analysis of Harvard collaborations with “Seven Sons” universities.
Harvard Global Research & Support Services, Inc. (2026). “International Grant Administration.” Current Harvard Global materials describe its separate-but-affiliated structure, sponsored-award process, use of Harvard University researchers and resources, GMAS documentation and foreign sponsors.
U.S. Department of Education, Federal Student Aid (2023; updated 2026). “Frequently Asked Questions: Section 117 Foreign Gift and Contract Reporting.” The guidance explains the Department’s treatment of intermediaries, reasonable due diligence and the institution’s ultimate compliance responsibility while expressly stating that the FAQ does not itself create new legal standards.
20 U.S.C. § 1011f. Section 117 of the Higher Education Act, governing disclosure of qualifying foreign gifts and contracts by federally assisted institutions of higher education.
U.S. Department of Education, Office of General Counsel (2020). Institutional Compliance with Section 117 of the Higher Education Act of 1965. The report reviews the 1986 legislative history and the Department’s renewed Section 117 enforcement effort.
U.S. Senate Permanent Subcommittee on Investigations (2019). China’s Impact on the U.S. Education System. The bipartisan staff investigation reported more than $158 million in direct Chinese funding for Confucius Institutes since 2006 and found substantial Section 117 underreporting among institutions exceeding the statutory threshold.
U.S. Department of Education, Office of Inspector General (2025). FSA’s Oversight of Section 117 Reporting Requirements, February 12, 2025. The OIG found that FSA lacked monitoring plans, policies and procedures for Section 117 oversight and issued six recommendations.
U.S. Department of Education (2025). “U.S. Department of Education Initiates Records Request from Harvard University After Discovering Inaccurate Foreign Financial Disclosures,” April 18, 2025, together with the underlying notice of investigation.
U.S. Department of Education (2026). “U.S. Department of Education Releases Latest Foreign Funding Disclosures from Federally-Funded American Universities,” February 11, 2026. Education reported more than 8,300 transactions worth over $5.2 billion for 2025, $67.6 billion disclosed since 1986, and stated that the majority of the historical total had been disclosed since 2019.
U.S. Department of Justice (2021, 2023). Charles Lieber conviction and sentencing materials. The records establish Lieber’s false statements and undisclosed Wuhan University of Technology and Thousand Talents relationships while also stating that those relationships were unbeknownst to Harvard.
U.S. Department of Defense (2023). “Department of Defense Strengthening Efforts to Counter Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education” and Policy for Risk-Based Security Reviews of Fundamental Research.
National Science Foundation (2022–2026). CHIPS and Science Act research-security implementation materials, including research-security training and malign foreign talent recruitment program certification requirements.
U.S. Department of War (2026). Updated Section 1286 foreign-institution list, identifying 130 academic and research institutions in China, Russia and Iran considered to present elevated risks of misappropriation of U.S.-funded research and development.
Seems as though our country has been supporting half the world. Leaches.