According to the Office of the Director of National Intelligence (ODNI)’s "Safeguarding Academia" bulletin, foreign espionage is targeting US universities – threatening research, reputations, and regulatory compliance. This alert distills key takeaways from the bulletin and outlines how DLA Piper can help higher education institutions proactively mitigate risks through its integrated policy and regulatory experience across a variety of national security and trade-related issues.
Background
On August 25, 2025, ODNI, through the National Counterintelligence and Security Center (NCSC) and other federal agencies, issued new guidance alerting US colleges and universities to “increasing foreign threats to their research and to arm them with mitigation strategies for addressing these threats.” In its announcement regarding the bulletin’s release, NCSC Acting Director James Cangialosi warned that “foreign adversaries are increasingly exploiting the open and collaborative environment of U.S. academic institutions.” ODNI’s bulletin provides detailed information regarding these threats and provides recommendations on mitigation efforts.
Highlights from the ODNI Bulletin
Academic innovation under siege
Foreign adversaries continue to systematically target US academic research, seeking to exfiltrate pre-publication data, intellectual property, laboratory protocols, and technical expertise. China, in particular, conducts persistent espionage operations against key and emerging technology sectors – ranging from artificial intelligence (AI) and quantum to semiconductors and hypersonics – to advance its economic and military objectives.
Expertise on the move: Talent-poaching risks
State-sponsored recruitment programs, including those outside of China, promise lucrative salaries, significant research funding, visas, and other incentives to US faculty, postdoctoral researchers, and students. These programs focus on experts in AI, semiconductors, quantum, biotechnology, and other advanced technologies. Participation in plans like China’s Thousand Talents or related initiatives likely risks export-control and sanctions violations, economic espionage, conflicts of interest, ownership of intellectual property, grant and tax fraud, and the long-term loss of federal funding.
Collaboration or compromise? Foreign research funding
Undisclosed foreign grants and partnerships can give adversaries unfettered access to taxpayer-supported research. Failure to reveal dual-funded projects and foreign collaborators not only violates grant terms, but also exposes institutions and investigators to administrative penalties, grant revocations, and potential criminal liability.
Coercion of the next generation: Student recruitment threats
Foreign intelligence services infiltrate US campuses by embedding operatives as students or leveraging fellow nationals to recruit promising researchers. Such coercion and transnational repression jeopardize academic freedom and may subject scholars to blackmail, threats to family back home, or forced collaboration.
Insiders and intruders: Internal and cyber threats
Trusted insiders – students, faculty, and administrators – can be manipulated or coerced by adversaries into misappropriating sensitive information. Adversaries also exploit cyber intrusion tactics (eg, phishing, malware, social engineering) and social media outreach to harvest credentials, steal terabytes of data, and blur lines between legitimate academic exchange and intelligence collection.
ODNI-suggested mitigation techniques
The bulletin included the following considerations for higher education institutions.
- Cultivate a culture of security and stewardship
- Conduct rigorous risk assessments of research projects and funding sources
- Implement robust travel, cybersecurity, and device hygiene protocols
- Strengthen reporting mechanisms and leverage government resources
- Provide tailored security education and ethics training
Broader implications for higher education institutions
Universities are encouraged to reconcile their mission of open collaboration with the bulletin’s warning that “academic openness can be exploited to facilitate espionage.” Institutions may face legal and reputational risks if foreign affiliations remain undisclosed, and the open information environment potentially invites insider threats and cyber intrusions. To maintain research excellence and institutional integrity, institutions are encouraged to adopt a comprehensive security posture that integrates disclosure of affiliations to foreign institutions, policy enforcement, technological controls, and community-wide training.
In addition to the various risks posed by foreign espionage activities, institutions with programs, faculty, or students affiliated with China likely run the risk of increased congressional scrutiny. The 119th Congress has taken significant steps in an effort to combat foreign influence in US higher education, including by advancing legislation expanding oversight and disclosure requirements for affiliations and contracts between US higher education institutions and foreign countries of concerns.
The House Select Committee on the Chinese Communist Party continues to receive bipartisan support and has been actively investigating interactions between US higher education institutions and Chinese-affiliated entities, including by calling on institutions to “end their schools’ partnerships with Chinese universities” and raising concerns about collaborations between US and foreign researchers. As congressional leaders return to Capitol Hill this fall, they are likely to continue efforts to combat foreign influence in higher education and congressional committees are likely to continue investigating universities that maintain significant involvement with Chinese institutions.
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