University Counsel Should Be Thinking About Foreign Influence Risks Holistically

At the end of July, colleges and universities that accept $250,000 or more in foreign funding must make their semiannual report to the Department of Education (ED) under Section 117 of the Higher Education Act. Historically, this information was rarely shared inside the government and never released to the public. Those days are over. ED officials now say the information will be shared across government agencies, including the Department of Justice (DOJ). Having spent years as a national security prosecutor, I read that shift plainly: the government wants compliance that reaches the actual risk, not compliance that checks a box.