An April 28, 2025 executive order directs the Secretary of Education to enforce a dormant section of the Higher Education Act that requires universities to report significant foreign funding, coordinating with the Department of Justice to hold non-compliant institutions accountable when they seek federal research dollars.

What does the order change?

The order argues that Section 1011f of the Higher Education Act of 1965 has not been "robustly enforced," according to the April 28, 2025 Federal Register notice. It urges the Secretary of Education to work with the Justice Department and other agencies to ensure universities disclose foreign funding when applying for federal grants, and to penalize those that do not. Research-compliance officers read the text as a near-immediate audit trigger for institutional conflict-of-interest filings.

How do the disclosure rules work today?

Since the Biden White House issued National Security Presidential Memorandum 33 implementation guidance on January 4, 2022, federal agencies have required grant applicants and host institutions to meet a standard set of security conditions. The framework remains in force under the second Trump administration.

Senior personnel listed on proposed studies must disclose:

• Organizational affiliations and employment outside the U.S.
• Current involvement in "malign foreign talent recruitment programs" — recruitment schemes operated by "foreign countries of concern" that pay participants to transfer U.S.-funded intellectual property abroad
• Foreign funding sources received or expected

Institutions receiving federal funds must establish:

• A cybersecurity program covering threat recognition training, access controls, and monitoring of sensitive data transfers
• A foreign travel security program offering device protection, safety briefings, and pre-trip authorization for faculty and staff teaching, conferencing, or conducting research abroad
• A general research security training program for researchers
• Export-control training where research falls under International Traffic in Arms Regulations or Export Administration Regulations

The 2022 rules descend from a 2021 presidential memorandum that conditioned federal funding on grant applicants making disclosures and joining "institutional research security programs."

Who is in the regulatory crosshairs?

The "countries of concern" language targets talent recruitment programs operated by the People's Republic of China and a small list of other states. Participants in those programs may receive cash, paid institutional appointments, or foreign speaking engagements in exchange for channeling U.S.-funded data, technology, or other intellectual property toward the host country's "military modernization goals or economic goals."

Why did the SAFE Research Act stall?

The most aggressive legislative proposal did not survive the FY2026 defense bill. House leaders in late 2025 pulled the SAFE Research Act from the National Defense Authorization Act after pushback from academic associations.

The Association of American Universities warned the bill would have prevented researchers seeking federal funds from having "nearly any agreement with a Chinese university," including "every single research agreement, every study abroad program, every language program, every professional conference, and every campus facility that a U.S. university might have in partnership with another institution abroad."

One professional association argued the restrictions would "chill collaboration, unfairly impact researchers, and undermine America's competitive edge in science and technology." A separate letter signed by faculty at 210 institutions argued the statute could be unfairly enforced against U.S. researchers of Chinese descent.

What enforcement signals are researchers reporting?

ProPublica reported in 2025 that Trump administration officials ordered federal agencies to scrutinize ties between U.S. researchers on federally funded projects and their foreign collaborators. One scientist told ProPublica the move was "a classic hallmark of authoritarianism, rather than a safety measure."

What's next for compliance teams?

The Education Department's coordination plan with DOJ has not yet been published. Research-security officers at large universities say they are drafting revised conflict-of-interest and foreign-engagement checklists while waiting for the next wave of agency-specific implementation rules — a process likely to shape grant submission procedures through 2026.