Reminder: Compliance with NASA’s China Restriction 

NASA has provided the SECURE Center with the following information for grantees: 

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NASA grant and cooperative agreement recipients are reminded that NASA is restricted by law from using appropriated funds to engage in bilateral participation, collaboration, or coordination with China or Chinese-owned companies. This restriction applies to all activities conducted under NASA awards.

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When submitting grant proposals, applicants’ Authorized Organizational Representatives sign an attestation affirming that the applicant will not engage in such restricted activities, at the prime recipient level or at any subrecipient level. Additionally, the NASA Grant and Cooperative Agreement Manual (GCAM, effective March 21, 2025) - which governs all NASA grants and cooperative agreements - contains explicit language regarding this restriction. See GCAM Section 9.4, Proposals Involving Non-U.S. Organizations, and Appendix A, Certifications, Assurances, and Representations, for specific language.

\The statutory basis for this restriction is found in NASA’s annual appropriations legislation. The most recent language is in Section 526 of the Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act (Pub. L. 119-74), and it states that neither NASA nor the Office of Science and Technology Policy (OSTP) may use appropriated funds to “develop, design, plan, promulgate, implement, or execute a bilateral policy, program, order, or contract of any kind to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company […].”

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What this means for your institution:

• Do not engage in bilateral coordination, collaboration, or participation with China or any Chinese-owned companies or Chinese universities, including individuals working for such entities, under your NASA award. This restriction includes direct sharing of NASA-funded research data through any means, including IT systems, as well as bilateral joint publications with authors affiliated with the Chinese government or Chinese companies or universities.

• Ensure all project activities comply with the terms and conditions of your award and the GCAM.

Failure to comply may result in remedies for noncompliance, including award termination, disallowed costs, or referrals for consideration of suspension or debarment proceedings.

For questions regarding NASA grants, please contact your NASA Grant Officer. This information is not legal advice. You should consult your own legal counsel regarding questions of compliance with the terms of your grant.

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U.S. Education Department Releases Foreign Funding Disclosure Data

The U.S. Department of Education (DoED) announced the release of updated foreign funding disclosures submitted by federally funded colleges and universities under Section 117 of the Higher Education Act as part of a broader federal effort to increase transparency.  Per DoED, the Section 117 data include more than 8,300 contracts and gifts from foreign sources, totaling over $5.2 billion in 2025. The press release contains a link to a new Section 117 Foreign Gift and Contract Public Transparency Dashboard.  The Dashboard includes a section for “Total Value of Transactions involving Counterparties of Concern by US Government List” providing data on funding reported by institutions with entities appearing on various U.S. government restricted lists (e.g., BIS Entity List, DoD 1286 List, OFAC Sanctions List). It is common practice among institutions of higher education to screen entities (e.g., donors, sponsors of research and other contracts) against U.S. restrictions. Since foreign entities are placed on these lists at various points in time, clarity will be sought on whether the Dashboard accounts for the point in time a university reported a contract or gift with the entity relative to the time that the entity was added to a U.S. government list.
 

Related reporting from Axios provides additional context, noting that the funding is highly concentrated and often reflects legitimate academic activity rather than covert influence. According to the Axios article, more than half of the reported funding went to just four universities, and major sources included countries such as Qatar, the United Kingdom, Switzerland, Japan, Germany, and Saudi Arabia. Experts interviewed expressed caution that Section 117 data can be difficult to interpret because it aggregates diverse transactions (including scholarships, tuition payments, and overseas campus operations) and may not accurately reflect the true origin or intent of funds, according to Axios.