Key Takeaways
- The Department of War released the Fiscal Year 2025 (FY25) update to the Section 1286 list, which flags foreign academic and research institutions suspected of facilitating unauthorized transfer of U.S.‑funded technology.
- The FY25 list contains 130 institutions located in China, Russia, and Iran that have been confirmed to engage in activities raising the risk of misappropriation of U.S. government‑sponsored research and development.
- Under Secretary Emil Michael emphasized that the update reinforces the Department’s commitment to safeguarding taxpayer‑funded research and preserving the integrity of the American scientific enterprise.
- Domestic researchers, universities, and industry partners are advised to exercise strict caution when considering collaborations, funding arrangements, or data‑sharing with any entity on the list.
- The Section 1286 list will be refreshed at least annually—or more frequently if intelligence or threat assessments warrant—ensuring it remains responsive to emerging risks.
- The full FY25 list is publicly accessible via the Department of War’s website, enabling stakeholders to conduct due‑diligence before engaging with foreign partners.
Background and Legal Mandate
The announcement originates from a statutory requirement embedded in the Fiscal Year 2019 National Defense Authorization Act (NDAA), specifically Section 1286. This provision compels the Department of War to maintain and periodically publish a list of foreign institutions that are deemed to be involved in “problematic activities” that could jeopardize the security of U.S. government‑funded research. The law reflects growing congressional concern over the strategic transfer of critical technologies—particularly those with dual‑use applications—to nations identified as competitors or adversaries. By mandating an annual update, Congress intended to create a living document that evolves alongside shifts in the global research landscape and intelligence assessments.
Scope and Composition of the FY25 List
For the FY25 cycle, the Department identified 130 academic and research institutions situated in the People’s Republic of China, the Russian Federation, and the Islamic Republic of Iran. Each entry on the list corresponds to an entity that, after thorough vetting by intelligence analysts and subject‑matter experts, has demonstrated a pattern of behavior that heightens the likelihood of unauthorized access to, or diversion of, U.S.-funded research outcomes. Examples of such activities include, but are not limited to, participation in talent‑recruitment programs that target U.S. scientists, involvement in joint projects that lack adequate safeguards against technology transfer, and receipt of funding streams that obscure the ultimate end‑use of shared knowledge. The Department emphasizes that inclusion on the list does not automatically imply illicit conduct; rather, it signals a heightened risk profile that warrants heightened scrutiny from U.S. partners.
Statement from Leadership
Under Secretary of War for Research and Engineering, Emil Michael, framed the release as a continuation of the Department’s broader strategy to protect the nation’s scientific assets. He stated, “The Department of War is strengthening its commitment to protect taxpayer‑funded research and preserving the integrity of the American scientific enterprise.” This wording underscores two intertwined objectives: first, safeguarding the financial investment made by the federal government in research and development; second, maintaining the credibility and openness of U.S. science, which relies on trust and transparent collaboration. By publicly naming institutions that pose a risk, the Department aims to deter malign actors while simultaneously encouraging responsible engagement practices among legitimate partners.
Guidance for Domestic Stakeholders
The announcement carries a clear directive for U.S. researchers, academic institutions, and private‑sector partners: exercise strict caution when contemplating any form of collaboration, funding, or data‑sharing with entities appearing on the Section 1286 list. The Department’s advice is not a blanket prohibition but a risk‑based recommendation intended to prompt due‑diligence procedures. Institutions are encouraged to:
- Verify Partner Status – Cross‑reference prospective foreign collaborators against the latest list before entering agreements.
- Implement Enhanced Safeguards – Apply additional export‑control reviews, cybersecurity measures, and monitoring mechanisms for projects involving flagged entities.
- Seek Legal Counsel – Consult with export‑control officers or legal advisors to ensure compliance with the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and other relevant statutes.
- Report Suspicious Activity – Promptly inform the Department of War’s Office of Research Security or appropriate oversight bodies if indications of technology diversion arise.
By embedding these practices into standard operating procedures, the academic and industrial communities can continue to reap the benefits of international cooperation while mitigating exposure to illicit technology transfer.
Process for List Maintenance and Updates
The Department committed to refreshing the Section 1286 list at least once per fiscal year, with the possibility of more frequent revisions should emerging intelligence or threat assessments necessitate immediate action. This flexible schedule ensures that the list remains a dynamic tool rather than a static snapshot. Updates will incorporate:
- Newly Identified Risks – Institutions discovered through fresh intelligence, open‑source analysis, or whistle‑blower disclosures.
- Status Changes – Removal of entities that have demonstrably mitigated concerning behaviors or have ceased operations.
- Refined Criteria – Adjustments to the definitions of “problematic activities” based on evolving threat landscapes, technological advancements, and lessons learned from prior enforcement actions.
Transparency is a cornerstone of this process; the Department will publish each revision on its official website, accompanied by a brief explanatory note outlining the rationale for additions or deletions. Stakeholders are therefore encouraged to monitor the site regularly or subscribe to notification services to stay abreast of changes.
Implications for National Security and Scientific Integrity
The publication of the FY25 list serves multiple strategic purposes. From a national‑security perspective, it aims to curtail channels through which adversarial states could acquire critical capabilities—such as advanced computing, aerospace materials, biotechnologies, or artificial‑intelligence algorithms—by exploiting gaps in overseas research partnerships. By highlighting institutions that present a heightened risk, the Department seeks to blunt the effectiveness of state‑sponsored talent‑acquisition programs and covert procurement efforts that have historically targeted U.S. research outputs.
From a scientific‑integrity standpoint, the list helps preserve the openness that underpins American innovation while discouraging exploitative practices that erode trust. When foreign actors misuse collaborative frameworks to siphon off proprietary knowledge, it not only harms the immediate victims but also damages the broader perception of the U.S. as a reliable partner in global science. The Department’s proactive stance thus endeavors to protect both the tangible assets (intellectual property, technical data) and the intangible reputation of American research institutions.
Conclusion
The Fiscal Year 2025 update to the Section 1286 list represents a concrete step in the Department of War’s ongoing effort to shield U.S.‑funded research from unauthorized transfer to foreign actors of concern. By naming 130 institutions across China, Russia, and Iran, the agency provides a actionable reference for researchers, universities, and industry partners seeking to navigate the complex terrain of international collaboration responsibly. The guidance to exercise strict caution, coupled with an annual review mechanism, balances the imperative of national security with the enduring value of open scientific inquiry. Stakeholders who heed these advisories will be better positioned to contribute to innovation while safeguarding the strategic interests of the United States.
Readers interested in reviewing the complete FY25 Section 1286 list can access it via the Department of War’s official portal, where the document is hosted alongside FAQs and contact information for the Office of Research Security.