Today, the U.S. Department of Education’s Office of the General Counsel (OGC) opened a foreign funding investigation into the University of Michigan (UM) after a review of the university’s foreign reports revealed inaccurate and incomplete disclosures. Pursuant to Section 117 of the Higher Education Act of 1965 (20 U.S.C. § 1011f), postsecondary institutions receiving federal financial assistance must disclose foreign source gifts and contracts with a value of $250,000 or more annually to the Department of Education.
“Despite the University of Michigan’s history of downplaying its vulnerabilities to malign foreign influence, recent reports reveal that UM’s research laboratories remain vulnerable to sabotage, including what the U.S. Department of Justice recently described in criminal charges as ‘potential agroterrorism’ by Chinese nationals affiliated with UM. As the recipient of federal research funding, UM has both a moral and legal obligation to be completely transparent about its foreign partnerships,” said Chief Investigative Counsel Paul Moore. “Unfortunately, tens of millions of dollars in foreign funding in UM’s disclosure reports have been reported in an untimely manner and appear to erroneously identify some of UM’s foreign funders as ‘nongovernmental entities,’ even though the foreign funders seem to be directly affiliated with foreign governments. OGC will vigorously investigate this matter to ensure that the American people know the true scope of foreign funding and influence on our campuses.”
To verify UM’s compliance with the law and the accuracy of its disclosures, ED’s investigation demands that UM produce certain records within thirty (30) calendar days including, but not limited to:
- Tax records related to foreign funding from January 1, 2020 through the present;
- A copy and full written narrative description of the university’s written procedures and administrative systems in place to achieve compliance with Section 117’s foreign funding disclosure requirements from January 1, 2020 through the present;
- A copy of each written agreement with a foreign government, foreign educational institution, foreign non-governmental entity, or foreign corporate entity relating to international student admissions (undergraduate and graduate), faculty, scholars, and any research personnel from January 1, 2020 through the present;
- A copy of each written agreement with a foreign government, foreign educational institution, foreign non-governmental entity, or foreign corporate entity detailing the participation of non-U.S. individuals or entities in university or university-affiliated research collaborations from January 1, 2020 through the present;
- Identification of university personnel and contract personnel (name, title, contact information) involved in the university’s assistance and/or efforts related to F-1 Student Visa (Academic Student), work permits, and travel for international students, faculty, and other personnel from January 1, 2020 through the present;
- A full and complete identification (name, title, contact information) of all university research personnel and contract personnel, undergraduate and graduate, involved in bilateral or multilateral research collaborations with non-U.S. research institutions (including foreign government agencies, foreign educational institutions, foreign corporations, non-governmental foreign entities, and foreign individuals) from January 1, 2020 through the present;
- A complete identification of all legally affiliated university partnerships, ventures, collaborations (bilateral and/or multilateral) or other official relationships outside of the United States between the university (and/or its affiliates) and any foreign government from January 1, 2020 through the present;
- Identification of university personnel or contract personnel (name, title, contact information) responsible for the oversight and/or administration of the university’s compliance with federal Foreign Government Talent Recruitment Program restrictions and/or export and import control regulations from January 1, 2020 through the present; and
- A complete list of all foreign gifts, grants, contracts, and/or restricted or conditional gifts, grants, or contracts between the university (and any university-affiliated entity) and any foreign source (to include individuals, governments, non-governmental entities, educational institutions, or corporate entities) from January 1, 2020 through the present.
Background
In January 2025, UM ended its two-decade-long partnership with Shanghai Jiao Tong University, a prominent university in China, after Chairman John Moolenaar of the U.S. House Select Committee on the Chinese Communist Party (CCP) issued a letter to UM raising concerns about the relationship between UM and its joint institute with the university. Specifically, the Select Committee identified China’s ability to use its joint research with UM to bolster the Chinese military’s “most sensitive defense programs, including nuclear weapons… and fighter jets.”
Last month, the U.S. Department of Justice (DOJ) issued a criminal complaint and, separately, brought forth criminal charges amid allegations that multiple Chinese nationals smuggled dangerous biological materials, potentially for agroterrorism, into the United States for use at UM laboratories. This scrutiny comes alongside probing inquiries issued by Chairman Moolenaar, Chairman Tim Walberg of the Committee on Education and the Workforce, and Chairman Brian Babin of the Committee on Science, Space, and Technology, which investigated the potential agroterrorism incident and urged federal entities to review their grants with the University of Michigan.
Today’s investigation into UM reflects the Trump Administration’s ongoing efforts to hold colleges and universities accountable for failing to comply with federal disclosure laws on foreign funding, consistent with President Trump’s Executive Order on Transparency Regarding Foreign Influence at American Universities.
Section 117 of the Higher Education Act mandates disclosure of foreign gifts above $250,000 to federally funded universities and is intended to protect national security and academic integrity by curbing undue foreign influence in higher education. Noncompliant institutions risk DOJ enforcement, including civil actions.
