Federal agencies have opened foreign-funding investigations into Duke University and the University of North Dakota over possible Section 117 disclosure issues.
The federal government has opened foreign-funding investigations into Duke University and the University of North Dakota, bringing renewed attention to how American colleges disclose international financial relationships and how those relationships are reviewed when universities conduct research in strategically important fields.
On September 16, 2026, the U.S. Department of Education and U.S. Department of State announced that compliance investigations had been opened into both institutions the previous day. Federal officials said reviews of university records raised concerns about possible incomplete, inaccurate, and untimely disclosures under Section 117 of the Higher Education Act.
Section 117 requires certain colleges and universities receiving federal financial assistance to report qualifying foreign gifts and contracts. According to the Education Department, institutions covered by the law must disclose foreign-source gifts and contracts valued at $250,000 or more annually.
The investigations do not establish that either university violated federal law. They are ongoing compliance reviews intended to determine whether the institutions properly met their reporting obligations.
Bottom Line: Federal officials are examining whether Duke University and the University of North Dakota properly disclosed certain foreign financial relationships. The investigations could provide an important indication of how aggressively the federal government plans to enforce transparency requirements involving international university partnerships, research funding, and research security.
Editorial Note
This article examines active federal investigations. The concerns raised by the U.S. Departments of Education and State are compliance allegations and questions, not final findings of wrongdoing.
Statements involving foreign entities, government relationships, military connections, or national-security concerns are attributed to federal officials where appropriate. New To Education has not independently reviewed the underlying financial records or determined that either institution violated Section 117.
It is also important to distinguish foreign funding from improper foreign influence. Universities routinely receive money from international students, research partners, companies, foundations, and governments. The existence of an international financial relationship does not itself establish misconduct.
Section 117 is fundamentally a transparency requirement. The current investigations concern whether reportable relationships were properly identified and disclosed.
This article is provided for educational and informational purposes and does not constitute legal advice.
What Happened
The Education and State Departments opened the Duke University and University of North Dakota reviews on September 15 and publicly announced them on September 16. The Education Department said its review of university records indicated possible problems involving the timing, completeness, and accuracy of some foreign-funding disclosures.
Federal officials also raised concerns about how some international partners were classified in university reporting. Both institutions have now been asked to provide additional records so investigators can evaluate their Section 117 compliance systems more closely.
The federal action places Duke and UND within a growing area of higher-education oversight focused on whether universities can accurately track complex international relationships across research programs, overseas partnerships, financial offices, faculty projects, and institutional agreements.
What Section 117 Actually Requires
Section 117 of the Higher Education Act requires covered higher-education institutions to disclose certain gifts and contracts received from foreign sources.
The Education Department says the reporting threshold is $250,000 or more annually. Reportable relationships can involve foreign governments, corporations, universities, foundations, or other international organizations.
The purpose is transparency rather than isolation from the rest of the world.
American universities routinely collaborate across borders. They enroll international students, conduct multinational research, establish overseas campuses, and enter partnerships with international organizations.
Those activities are normal parts of modern higher education.
The compliance issue begins when a financial relationship covered by federal law is not disclosed accurately, completely, or on time.
Why Duke University Is Under Review
The Duke investigation includes scrutiny of the university's international relationships, particularly those connected to Duke Kunshan University in China.
Duke Kunshan University was developed through a partnership involving Duke University and Wuhan University. In announcing the investigation, federal officials pointed to concerns involving Wuhan University's relationships with China's technology and defense sectors as part of the government's rationale for additional review.
That allegation should be described carefully.
The investigation does not establish that Duke University, Duke Kunshan University, or Wuhan University violated U.S. law.
The central compliance question is whether Duke properly identified and reported financial relationships that fall within Section 117.
Federal investigators have given Duke 30 calendar days to provide additional records. The request extends beyond individual transactions and includes information intended to help investigators understand how the university identifies foreign entities, tracks international research relationships, and determines when federal reporting is required.
That suggests investigators are examining Duke's broader compliance structure rather than simply looking for one incorrectly reported transaction.
Why the University of North Dakota Is Under Review
The University of North Dakota investigation is particularly connected to the university's aerospace and uncrewed-aircraft research.
UND has a significant aviation and aerospace presence, including work involving uncrewed aircraft systems and related technologies. Federal officials said some of the university's international aviation relationships warrant additional review because of alleged connections between certain foreign entities and Chinese military or state-linked organizations.
Those statements are part of the federal government's justification for opening the investigation. They are not findings that UND improperly transferred technology or violated federal law.
UND has also been given 30 days to provide records covering foreign financial activity, research collaborations, foreign-government talent programs, international agreements, and the university's internal Section 117 compliance procedures.
As with Duke, the federal review appears to extend beyond individual payments and into the systems the university uses to identify and report international relationships.
Why Research Security Matters Here
The investigations are primarily about disclosure, but they also intersect with the larger issue of research security.
American universities increasingly collaborate internationally in fields such as artificial intelligence, aerospace, biotechnology, engineering, cybersecurity, medicine, and advanced manufacturing. Those relationships can produce major scientific, educational, and economic benefits.
Some university research can also involve technologies with commercial, military, or national-security applications.
That creates additional responsibilities involving transparency, export controls, contractual obligations, access to research, and federal reporting.
The goal should not be to treat international collaboration as inherently suspicious. The practical issue is whether institutions know who their partners are, understand the financial relationships involved, and have systems capable of meeting federal disclosure and security requirements.
What This Means for Universities
The Duke and UND investigations send a broader message to institutions with extensive international activity.
Large research universities can maintain hundreds or thousands of relationships spread across departments, laboratories, foundations, faculty projects, overseas campuses, and corporate partnerships. Information known to one part of a university may also be relevant to its research-security staff, general counsel, grants office, finance department, or federal compliance team.
That complexity makes internal coordination increasingly important.
Universities need systems capable of identifying foreign entities correctly, connecting financial information across departments, documenting international research relationships, and determining when a transaction or agreement triggers federal reporting requirements.
For institutions with substantial global operations, foreign-funding compliance can no longer be treated as an isolated accounting task.
What This Means for International Education
The investigations also raise a broader question about how universities can strengthen oversight without damaging legitimate international education.
International students, visiting scholars, joint-degree programs, overseas campuses, and cross-border research partnerships are normal parts of modern higher education.
Strong oversight should therefore focus on actual conduct, financial relationships, contractual obligations, research access, disclosure requirements, and verified security concerns rather than treating nationality itself as suspicious.
Transparency and international collaboration do not have to be competing goals.
Universities can maintain global partnerships while also ensuring that major financial relationships are documented and disclosed as required.
What This Means for Students and Families
For students and families, Section 117 may initially sound like a distant federal reporting rule.
The broader issue is institutional transparency.
Students attend universities that receive federal support, conduct internationally connected research, and enter agreements with outside organizations. Families reasonably expect those institutions to understand who their significant financial partners are and to follow applicable disclosure requirements.
At the same time, the existence of a federal investigation should not automatically be interpreted as proof of misconduct.
Compliance reviews can lead to corrected records, stronger internal procedures, additional federal oversight, or findings that institutions substantially complied with the law.
For students and families, the immediate takeaway is therefore not that Duke or UND has been found guilty of wrongdoing. It is that federal scrutiny of large international financial relationships in higher education is increasing.
The Bigger Picture
The Duke and UND investigations are part of a broader federal emphasis on higher-education accountability and foreign-funding transparency.
The Education Department has recently placed greater attention on research integrity and improper foreign influence as part of its broader higher-education agenda. In August, Education Secretary Linda McMahon called on universities to explain publicly how they intend to address research integrity and foreign influence alongside issues such as admissions, artificial intelligence, affordability, free speech, and workforce preparation.
Section 117 enforcement gives that broader concern a specific legal framework.
Rather than asking generally whether universities have international relationships, federal investigators can examine whether particular financial arrangements were reportable and whether institutions properly disclosed them.
That distinction matters because it grounds oversight in specific legal requirements rather than broad suspicion of international education.
What Happens Next
Duke and the University of North Dakota have been directed to provide requested records within 30 calendar days.
Federal officials will then examine those materials and determine whether the institutions complied with Section 117.
The reviews could result in findings that the universities substantially complied with federal requirements, requests for corrected reporting, additional compliance measures, or further enforcement if investigators identify significant violations.
At this stage, those outcomes remain uncertain.
No final federal determination has been announced against either institution.
Why This Matters
The larger issue is not whether American universities should stop working internationally.
Modern research universities depend heavily on global collaboration.
The more important question is whether those relationships are transparent enough for university leaders, students, taxpayers, and federal agencies to understand who is providing significant funding and what obligations accompany those relationships.
Foreign funding is not automatically improper, and an international partnership is not automatically a security risk.
But when federal law requires disclosure, institutions need systems capable of identifying those relationships accurately and reporting them on time.
The Duke and UND investigations may provide an early indication of how aggressively federal officials intend to enforce those expectations.
Key Takeaways
- The Education and State Departments announced the Duke and UND investigations on September 16, 2026.
- The compliance reviews began on September 15.
- Federal officials allege possible incomplete, inaccurate, or untimely Section 117 disclosures.
- Section 117 requires covered institutions to report qualifying foreign gifts and contracts valued at $250,000 or more annually.
- Duke's review includes scrutiny of international relationships connected to Duke Kunshan University and Wuhan University.
- UND's investigation includes international relationships connected to its aerospace and uncrewed-aircraft research.
- Both institutions have been given 30 days to provide additional records.
- The investigations are not final findings of wrongdoing.
Frequently Asked Questions
Have Duke or UND been found to have violated federal law?
No. These are ongoing federal compliance investigations. Government officials have raised concerns about the institutions' disclosures, but no final violation has been announced.
What is Section 117?
Section 117 of the Higher Education Act requires covered colleges and universities to disclose certain gifts and contracts received from foreign sources.
What happens next?
Both universities must provide requested records to federal investigators. The agencies will review those materials before deciding whether corrective action or additional enforcement is warranted.
Final Thoughts
American universities increasingly operate as global institutions. Students cross borders, researchers collaborate internationally, universities establish overseas campuses, and academic partnerships routinely involve institutions, companies, and governments outside the United States.
That global reach creates significant educational and scientific opportunities, but it also creates responsibilities.
Universities receiving federal support need systems capable of tracking major foreign financial relationships, identifying who their partners are, and determining whether federal disclosure rules apply.
The Duke and University of North Dakota investigations have not established that either institution broke the law. What they do show is that federal scrutiny of foreign financial relationships in higher education is increasing.
For universities with extensive international partnerships, strong systems for transparency, reporting, and research security are becoming increasingly important.
Support New To Education
New To Education provides educational news, research, legal analysis, practical resources, tutoring support, and learning tools for students, educators, families, and lifelong learners.
Support helps New To Education continue expanding free educational content, tutoring access, AI and smart-learning tools, education resources, website and app development, and new platform features.
Related Articles
Education Secretary Urges Colleges to Publicly Commit to Admissions, AI, Free-Speech, and Affordability Reforms
This New To Education article examines a broader federal push for higher-education accountability, including artificial intelligence, affordability, admissions, research integrity, foreign influence, and free speech.
U.S. Department of Education Introduces New Accountability Rules for Colleges and Universities
This New To Education article examines federal efforts to increase transparency and accountability across higher education, particularly around student outcomes and institutional responsibility.
Federal Government Opens New Review of TRIO Programs Serving First-Generation and Low-Income Students
This New To Education article examines another federal higher-education review and how changes in oversight and evaluation can affect institutions and students.
NTE Coverage Standard
New To Education prioritizes primary sources, including government records, legislation, court filings, official datasets, and original research.
In legal and regulatory coverage, New To Education distinguishes between allegations, investigations, agency positions, compliance reviews, preliminary findings, final enforcement actions, and judicial decisions.
An investigation does not establish wrongdoing. Statements concerning Duke University, the University of North Dakota, Wuhan University, foreign entities, or other institutions are attributed to federal agencies where appropriate and should not be interpreted as independent findings by New To Education.
This article is provided for educational and informational purposes and does not constitute legal advice.
Sources
U.S. Department of Education — September 16, 2026
The Department's official announcement is the primary source for the investigations, Section 117 reporting threshold, federal concerns, and records requests.
Read the official federal announcement
New To Education — Higher Education Accountability Coverage
New To Education's existing higher-education reporting provides additional background on federal accountability, research integrity, institutional transparency, and related policy developments.
