The Campus Review
September 17, 2026
The U.S. Department of Education and the U.S. Department of State have opened a joint investigation into UND foreign funding disclosures at the University of North Dakota.
Federal officials said their review identified concerns involving incomplete, inaccurate, and untimely reporting under Section 117 of the Higher Education Act. The investigation will examine the university’s foreign gifts and contracts, as well as its reporting practices.
Federal officials are also seeking records related to UND’s foreign financial relationships and partnerships. The University of North Dakota investigation comes as federal agencies increase scrutiny of how U.S. universities disclose foreign financial ties, particularly when institutions receive federal support for research involving advanced technologies.
| Quick Facts | Details |
| Institution | University of North Dakota (UND) |
| Investigating Agencies | U.S. Department of Education (ED) & U.S. Department of State |
| Statutory Authority | Section 117 of the Higher Education Act of 1965 |
| Statutory Threshold | Foreign gifts or contracts totaling $250,000 or more per calendar year |
| Inquiry Scope | Reporting compliance, disclosure accuracy, and institutional oversight |
| Response Deadline | 30 calendar days to produce requested documentation |
| Associated Inquiry | Parallel investigation opened regarding Duke University |
University of North Dakota Under Federal Investigation
The agencies opened the investigation alongside a parallel inquiry into Duke University. Both universities have received significant taxpayer support for research involving critical and emerging technologies. Pursuant to Section 117 of the Higher Education Act of 1965, postsecondary institutions receiving federal financial assistance must disclose foreign gifts and contracts valued at $250,000 or more annually.
The announcement came after a September 15 House Foreign Affairs Subcommittee hearing that examined alleged covert influence operations involving China and Cuba.
“Section 117 requires that institutions of higher education clearly and accurately report their foreign financial ties in a timely manner to ensure public transparency and as a condition of participating in the federal student aid programs,” said Under Secretary of Education Nicholas Kent.
“We expect these universities will cooperate fully. The Department of Education and the Department of State will continue to work together to vigorously ensure the integrity and accountability of our nation’s colleges and universities in reporting their foreign gifts and contracts.”
Why Federal Agencies Are Investigating UND Foreign Funding
The UND foreign funding probe centers on the university’s reporting of foreign gifts and contracts under Section 117. The Section 117 Partnership brings together the Education Department and State Department to improve the accuracy and transparency of foreign gift and contract reporting by U.S. colleges and universities. Federal scrutiny of university funding has also affected other institutions, including Temple University.
Agency officials identified several reporting gaps in their reviews:
- Disclosures submitted past statutory reporting deadlines.
- Filings that omitted key details about the nature and source of foreign contributions.
- At least one foreign government partner mischaracterized as a non-governmental entity.
“Our reviews found real gaps in how Duke and UND have handled their Section 117 obligations, including disclosures submitted late, key details left out, and at least one foreign government partner mischaracterized as a non-governmental entity,” said Under Secretary of State for Public Diplomacy Sarah B. Rogers.
“The law is clear: colleges and universities must report foreign gifts and contracts accurately and on time. We expect Duke and UND will work with us transparently as this review moves forward.”
What Section 117 Requires From Universities
Section 117 mandates clear public disclosures for institutions receiving federal assistance. The Education Department says Section 117 is intended to protect national security and academic integrity by improving transparency around foreign financial ties and curbing undue foreign influence in higher education.
| Core Obligation | Regulatory Requirement |
| Reporting Threshold | Disclose any gift received from or contract entered into with a foreign source valued at $250,000 or more, considered alone or combined across a calendar year. |
| Reporting Deadlines | File statutory reports twice annually by January 31 and July 31. |
| Entity Classification | Accurately distinguish whether a foreign partner is a foreign government, private corporation, individual, or non-governmental organization. |
| Internal Accountability | Maintain functional institutional controls to capture qualifying overseas funds across all university departments. |
What Federal Officials Are Asking UND to Provide
To verify compliance and assess the accuracy of previous disclosures, federal agencies directed the University of North Dakota to produce specific records within 30 calendar days.
The required documentation includes:
- Tax records related to foreign gifts and contracts that the university provided to the IRS, Department of the Treasury, and Federal Election Commission.
- Verification of the adequacy of institutional controls, documents, and records related to UND’s Section 117 compliance structure.
- Records related to UND’s agreements with foreign entities regarding international students, faculty, and research personnel.
- Documentation concerning international research collaborations and participation in foreign government talent programs.
- Copies of UND’s reportable foreign gifts, grants, and contracts.
What Happens Next in the Investigation
The UND foreign funding investigation will examine the records submitted by the university and assess whether its previous disclosures met Section 117 requirements.
The Education Department says institutions that fail to comply with Section 117 may face several forms of federal enforcement:
- Enforcement action by the Department of Education’s Office of the General Counsel.
- Referral to the U.S. Department of Justice.
- Civil actions to recoup the costs of federal investigation and enforcement.
- Repercussions that may jeopardize the institution’s continued participation in Title IV federal student aid programs.
The federal review of UND will assess whether it complied with its Section 117 reporting obligations and whether further federal action is warranted.
