DoD is Addressing Foreign Influence in Academia

DoD Addresses Foreign Influence
Photo by Kevin Ku

The Department of Defense (DoD) is addressing foreign influence in academia with the publication a foreign entities list that includes threats to U.S. national security.  This was announced in an address from Heidi Shyu, Under Secretary of Defense for Research and Engineering (USD R&E). 

By adding this requirement for screening of potential partners, the Pentagon is attempting to ensure money is not going to projects that involve one of the blacklisted entities that harvest U.S. technology secrets or have relationships with intelligence organizations in the Peoples Republic of China and Russia.

The release of this list was a requirement under the 2019 Defense Authorization Act.  This action was specifically undertaken to ensure that research and development initiatives funded by the DoD remain secure and that information gained is not stolen by foreign governments.  The DoD is encouraging academic institutions, the research community, and industry partners to remain vigilant and exercise caution when selecting research partners.  

Entity List Part of a Continuing Effort

This latest effort by the DoD is part of a continuing to protect the integrity of science and technology research.  In June of 2023 Shyu signed in a policy that directs research enterprises engaged in DoD research projects to evaluate potential financial conflicts of interest or commitments. 

Additionally, the National Science Foundation’s (NSF) has released list of documents that outline procedures for risk assessments for preventing the misappropriation of research and development efforts.  These actions set disclosure requirements for participants in federally funded research, to reveal potential conflicts of interest or commitment.  They also provide “clear messaging” about what constitutes acceptable behavior with regard to foreign interests.  

In December of 2020, the Government Accountability Office (GAO) released a report calling for enhanced policies for addressing foreign influence in federal research.  It sought to find means for combat undue foreign influence while maintaining an open research environment.

U.S. federal agencies have thwarted numerous attempts by China to steal U.S. defense sector technologies.  Recent enforcement activities as reported by Military Times, included the indictment of Chinese nationals who were involved in a campaign to turn U.S. citizens into spies.  These individuals are part of an entity defined in this released list.

Addressing Soft Power Espionage

The federal government is also addressing indirect espionage by Trojan Horse institutions that encourage research organizations to disclose sensitive information.  The Confucius Institutes is such an organization in that it attempts to attain information by convincing professors and students that China does not pose a threat and can benefit their research initiatives.

Confucius Institutes have been sponsored by the Chinese government since 2004 in universities around the world in an effort to carry out a number of propaganda objectives.  While many have closed as a consequence of governmental actions, they have often later reappeared under various titles. 

Complexities Involved in Maintaining Compliance

Universities and research laboratories face numerous regulatory boundaries with regard to export controls on information.  However, additional compliance requirements are invoked by the Department of Defense.  These requirements may vary across departments or agencies within the DoD.  As such these institutions should exercise due diligence with regard to the risks involved in any research activities.

CVG Strategy Export Compliance Management Programs

The DoD is addressing foreign influence in academia to protect U.S. national and economic interests.  These threats are present in all sectors including developers of defense items and items with dual-use capabilities.  It is the responsibility of all organizations involved in export or deemed exports to seriously consider export compliance requirements.

If you are part of a large corporation or a small company with a part-time compliance person, CVG Strategy has the compliance and training programs to help you meet International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) rules and requirements.  As the BIS place controls on a growing number of technologies it becomes increasing difficult for smaller businesses to stay abreast of regulatory developments.  Because of this, we provide Export Compliance Management Programs (ECMP) for businesses of all sizes.  

CVG Strategy, LLC is recognized the world over as the premier provider of Export Compliance Consulting and Export Compliance Programs for businesses involved in export in the U.S. and Canada.  We also provide the essential training that ensures that your team is up to date on governmental regulations, including the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), the Canadian Controlled Goods Program, and Office of Foreign Asset Controls (OFAC) and other regulatory agencies and more.

Kevin Gholston

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