Background
On August 17, 2026, the Department of War issued formal notifications to 30 domestic academic institutions directing them to initiate immediate and comprehensive reviews of their academic, financial, and research collaborations with foreign entities of concern. The notifications were executed by the Office of the Under Secretary of War for Research and Engineering and announced in a press release from the Department.
The action targets active institutional ties and collaborations with foreign entities identified under Section 1286 of the FY19 National Defense Authorization Act, as well as organizations associated with rebranded Confucius Institutes. Confucius Institutes, funded by the Chinese government, were established on campuses nationwide ostensibly as cultural exchange programs. The Department’s focus on “rebranded” institutes suggests concern that some programs may have continued operating under different names.
The Department’s list of problematic entities reportedly includes 130 organizations from China, Russia, and Iran, ranging from electronic measurement laboratories to scientific research centers.
Compliance Requirements
To maintain eligibility for future federal research funding, notified universities must take the following steps by August 31, 2026: (i) complete a comprehensive audit of all identified foreign collaborations; (ii) assess exposure of sensitive or export-controlled research to foreign entities; (iii) implement strict mitigation plans, including the termination of problematic partnerships; and (iv) report findings and actions directly to the Department.
Congressional Coordination
The Department is pursuing this effort alongside partners in Congress, including the House and Senate Armed Services Committees, the House and Senate Appropriations Committees, and the House Select Committee on the Chinese Communist Party. This coordination signals a bipartisan, multi-branch commitment to protecting federally funded research from foreign exploitation.
Next Steps
Institutions should act now to assess and address their exposure. First, all recipients of federal funding (including those not notified by the Department) should review their foreign collaboration portfolios—particularly ties to entities in China, Russia, and Iran—against the Section 1286 list and known Confucius Institute affiliates. Institutions should also evaluate the status and effectiveness of their export control compliance protocols. To the extent potentially problematic partnerships, as described in the notice, or export control gaps are identified, institutions should consider whether and what mitigation they can and are willing to implement.
Further, institutions should engage internal stakeholders and counsel early, as responding to the Department’s mandate, or preparing for potential future inquiries, will require close coordination among senior leadership, governing boards, general counsel, research offices, and compliance personnel. Given the extremely compressed August 31, 2026 deadline, this process should begin promptly for noticed institutions.
McGuireWoods will continue to closely monitor expanded actions, as the Department has indicated that these audits will help it identify emerging risks and respond to changing threat patterns, suggesting that this initiative may grow in scope or be followed by additional requirements. McGuireWoods has prepared a team internally that can assist targeted colleges and universities, if and as needed. Whether you have received one of the notices, it is important for all research institutions—particularly R1 institutions—to understand that this security audit has occurred and could expand into a larger regulatory matter.
For questions or assistance on evaluating your response to the Department’s letter, contact the authors or a member of McGuireWoods’ Higher Education Enforcement & Regulatory Counseling Practice Group.