In recent months, the U.S. academic and research community has been subject to intense scrutiny over ties to China. Even more than the controversial China Initiative of the first Trump administration, the past eight months have seen regulators, law enforcement, and Congress aggressively target U.S. scientists, universities, and academic medical centers through investigations to identify potentially inappropriate connections to China. Although China-related inquiries are of course only one aspect of the U.S. government's focus on universities, they require careful attention and calibrated responses because of the potential exposure for institutions and their faculty.
The U.S. government signaled its renewed focus on academia’s China connections in a recent publication on the national security risks of international collaborations. On August 25, 2025, the U.S. Department of Education, National Counterintelligence and Security Center, and other federal partners issued guidance in a joint bulletin, “Safeguarding Academia: Protecting Fundamental Research, Intellectual Property, Critical Technologies, and the U.S. Research Ecosystem.” The bulletin specifically names China as the top threat. It also describes favorite “targets” of foreign adversaries that seek to undermine U.S. national security:
- Students, faculty, researchers, and administrators with access to research and technical information
- Pre-publication research results and data
- Proprietary techniques and processes
- Research and laboratory procedures
- Practical knowledge and technical expertise
- Laboratory equipment, software, and computing resources
- Physical and virtual access protocols and passwords
- Budget estimates and grant information
- Prototypes or blueprints
- Student, employee, customer, or U.S. person data
All of this has led representatives from the FBI, State Department, Commerce Department, and other agencies to visit campuses at a breakneck pace, to seek information, offer tips, and generate dialogue to stay vigilant about inappropriate foreign activity.
The bulletin emphasized that these renewed concerns fundamentally lie with the Chinese government and the Chinese Communist Party (CCP) – not the Chinese people or Chinese Americans. But such assurances may provide little comfort to institutions that find themselves subject to investigations, enforcement actions, or Congressional inquiries. This renewed scrutiny has besieged almost all academic and research cooperation with China, making even routine business travel to mainland China more complex than in years past.
The government’s reinvigorated focus follows several U.S. government investigations and prosecutions – many of which are public – arising under the first Trump administration’s China Initiative that were either closed, dismissed, or ended in a favorable resolution. Yet the scope of the government’s focus today is broader than those prior initiatives.
Activities that attract the government’s interest run the spectrum of academia’s links with China based researchers, institutions, and organizations. The examples below – some of which predate the current Trump administration – illustrate the range of matters that have drawn federal probes in recent months:
- Joint education programs with China based universities
- Scholarship funding from China based organizations
- Enrollment of Chinese national students in advanced STEM programs and federally funded research
- Participation in Malign Foreign Talent Recruitment Programs
- Researcher affiliations, associations, and collaborations that require risk mitigation plans -- especially under DoD’s Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education
- Co-authoring articles with Chinese institutions in sensitive fields, such as advanced semiconductors, quantum technologies, artificial intelligence, optics, hypersonics, and energy systems
- Conflicts of interest, conflicts of commitment, and outside activity involving China
- Performance sites in China
- Current and pending support from China as disclosed (or undisclosed) in grant applications and progress reports
- Export control relative to materials exchange or production of equipment with Chinese counterparts
- Foreign gift and contract reporting under the US Department of Education’s Section 117 reporting requirement and NSF’s Foreign Financial Disclosure Report
- Use of prohibited Chinese telecommunications equipment under Section 889 of the 2019 National Defense Authorization Act
- Cyber intrusions that originate from China
- Travel to China to attend conferences, present papers, or develop business
- Cross-border data transactions including under DOJ’s new bulk data transfer rules
- Chinese delegations visiting campus or touring facilities
A cornerstone of academic excellence always has been international engagement. But with bipartisan support for the “tough on China” approach and real enforcement risks, striking the right balance may prove particularly challenging in the months and years ahead. And, institutions facing federal scrutiny – whether in the form of a subpoena, civil investigative demand, information request, or other inquiry – must ensure their compliance with legal obligations when responding to the government.
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