United States issues updated Section 1286 list of foreign institutions engaging in problematic activities
Date of publication: July 27, 2026.
The U.S. Department of War (formerly Defense) has published the Fiscal Year 2025 update to the list of foreign academic and research institutions engaging in problematic activities under Section 1286 of the Fiscal Year 2019 National Defense Authorization Act, with the objective of countering unauthorized transfer of U.S. government-funded technology to foreign countries of concern.
The new measures designate and block:
- Formal identification of 130 foreign academic and research institutions located in China, Russia and Iran as engaging in activities that increase the likelihood of misappropriation of U.S. government-funded research and development
- Advisory guidance urging strict caution by U.S. researchers, academic institutions and industry partners when considering collaboration, funding or data-sharing engagements with any institution named on the updated list
- An ongoing commitment by the War Department to review and update the Section 1286 list at least annually, or as appropriate, based on emerging intelligence and threat assessments
Since the FY2019 National Defense Authorization Act mandated creation of this list under Section 1286, the Department of War has used it as a tool to highlight institutions whose activities may facilitate adversarial government interference and threaten U.S. national security and scientific integrity, with the FY2025 update continuing this effort by expanding and formalizing the list of named institutions.
Conclusion
The FY2025 update to the Section 1286 list reinforces U.S. efforts to protect taxpayer-funded research from misappropriation by foreign institutions in countries of concern.
Companies should review the updated list, assess any direct or indirect relationships with listed institutions, and adjust collaboration, funding and data-sharing practices to align with the Department of War's advisory guidance.
These changes have been updated in ONESOURCE Global Trade Content. For more information on how ONESOURCE Global Trade solutions can assist you in managing restricted party screening, please contact your Account Manager or Customer Success Manager.