Zero-Dollar Foreign Gift Reporting: New Bill Pushes College Data to FBI and DNI Within 10 Days

The aptly named “Safeguarding American Education From Foreign Control Act” is looking to radically overhaul how U.S. colleges and universities report financial dealings with foreign entities. Think of it as putting a national security lens on every international research grant or donation a school receives.

The New Rules of Foreign Money

Right now, schools already have to report big foreign gifts and contracts. This bill tightens those screws significantly. Under this proposal, if a foreign source is not from a “covered nation,” the reporting threshold stays relatively high: the school only has to tell the Department of Education (DoE) about gifts or contracts totaling $250,000 or more in a calendar year. But here’s the kicker: If the money comes from a source associated with a “covered nation”—a term defined in a separate defense law (10 U.S.C. § 4872(f)(2))—the reporting threshold drops to zero dollars. That means if a university researcher gets a $500 grant or a professor receives a small travel stipend from an entity in a covered nation, the school must file a detailed disclosure report with the DoE by January 31st or July 31st.

The Intelligence Agency Fast-Track

This is where the bill shifts from administrative oversight to national security surveillance. Under the current system, the Department of Education handles these disclosures. This bill mandates that once the Secretary of Education receives any disclosure report, document, or record, they have only 10 days to send a copy to both the Director of the Federal Bureau of Investigation (FBI) and the Director of National Intelligence (DNI). This creates a direct, rapid pipeline of academic financial data straight into the hands of federal intelligence agencies.

The Retroactive Data Dump

If you thought the 10-day rule was intense, consider the retroactive requirement. The bill demands that within 90 days of enactment, the Secretary of Education must transfer all existing reports, documents, and records previously collected under this reporting section—even those from closed investigations—to the FBI Director and the DNI Director. This means decades of data on foreign academic funding relationships, much of which was collected under the assumption of DoE oversight, will be handed over to intelligence agencies en masse. For universities, this is a massive shift in regulatory focus, treating academic partnerships much like potential espionage vectors.

What This Means on the Ground

For university administrators and researchers, this means significantly more paperwork and risk. The zero-dollar reporting threshold for “covered nations” could create a massive compliance burden, forcing schools to track every single minor transaction, potentially leading them to simply avoid any partnership with entities from those nations altogether, even for non-sensitive academic exchanges. Think about the impact on a Ph.D. student who relies on a small international fellowship or a collaborative research project that requires minor funding exchanges—the administrative headache alone could be enough to kill the project. By funneling all this data immediately to the FBI and DNI, the bill prioritizes national security concerns over academic freedom and international collaboration, potentially chilling valuable research and educational exchange.