University Counsel Should Be Thinking About Foreign Influence Risks Holistically

Short summary

Universities accepting $250K+ in foreign funding must now report under Section 117, with data shared across agencies including DOJ. The article argues institutions should treat foreign influence compliance holistically across Section 117, FARA, the False Claims Act, FCPA/FEPA, and export controls rather than siloed regimes. AI and data analytics are increasingly used by the government to detect potential violations.

• •Section 117 reports now shared across government agencies including DOJ, raising enforcement risk for universities
• •Compliance should be holistic across Section 117, FARA, FCA, FCPA/FEPA, and export controls
• •AI and data analytics are being used by government to detect potential compliance violations

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