The US Department of Education and the US Department of State have opened an investigation into how Duke University reports its foreign gifts and contracts.
Federal officials say Duke’s disclosures were late and incomplete. In at least one case, they say, the university labeled a foreign government partner as a private one.
The investigation was opened Sept. 15 and announced the next day. The University of North Dakota (UND) is under a separate investigation announced at the same time.
Under Section 117 of the Higher Education Act, colleges that receive federal money must report any foreign gift or contract worth $250,000 or more. Schools that don’t report can lose access to federal student aid.
“Unfortunately, it appears that both Duke and UND have provided untimely and incomplete foreign funding disclosures, which include erroneously identifying certain governmental partners as ‘non-governmental,’” said undersecretary of education Nicholas Kent. “Section 117 requires that institutions of higher education clearly and accurately report their foreign financial ties in a timely manner — to ensure public transparency and as a condition of participating in the federal student aid programs.”
Duke did not address the specific allegations.
“Duke University received correspondence from the U.S. Department of Education and the U.S. Department of State regarding compliance with federal foreign gift and contract reporting requirements,” a university spokesperson said in a statement to Carolina Journal. “We are reviewing the letter carefully. Duke is committed to complying with the law and will continue to do so in a manner that is consistent with our academic mission.”
The investigation centers on Duke Kunshan University. Duke opened the joint campus with China’s Wuhan University in 2013 in Kunshan, a city in Jiangsu province.
Federal officials say Wuhan University is overseen by China’s State Administration of Science, Technology and Industry for National Defense. The announcement cites a 2025 letter from the House Select Committee on the Chinese Communist Party, which said the university “trains [China’s] cyber warfare specialists.”
The notice of investigation says the Chinese government requires joint campuses such as Duke Kunshan to be governed by China’s Ministry of Education. It also says each campus must include a Communist Party unit that monitors operations and has a say over major administrative decisions. Federal officials say Duke Kunshan’s leadership includes prominent Chinese government and Wuhan University officials.
Duke has 30 days to hand over records. Investigators are seeking a bevy of document dumps, including tax filings on Duke’s foreign activities, documents showing how the university tracks and reports foreign money, and agreements with foreign entities that cover international students, faculty, and researchers.
They also want records on Duke’s overseas research partnerships, any Duke employees who have joined foreign government talent programs, and copies of every foreign gift, grant, and contract the university was required to report.
“Our reviews found real gaps in how Duke and UND have handled their Section 117 obligations — disclosures submitted late, key details left out, and at least one foreign government partner mischaracterized as a non-governmental entity,” said undersecretary of state for public diplomacy Sarah B. Rogers.
“The law is clear: colleges and universities must report foreign gifts and contracts accurately and on time,” Rogers added. “We expect Duke and UND will work with us transparently as this review moves forward. The State Department remains committed to partnering with the Department of Education to hold higher education institutions accountable for full and honest disclosure of their foreign funding.”
This is the second federal action targeting Duke’s overseas ties since August. On Aug. 17, the Department of War ordered Duke and 29 other universities to review their academic, financial, and research collaborations with foreign entities of concern. As Carolina Journal reported at the time, UNC-Chapel Hill was also on the list. Findings were due to the department Aug. 31.
The announcement came a day after a House Foreign Affairs subcommittee hearing on what lawmakers called “covert malign influence” operations by China and Cuba.
Schools that break the reporting law can be sued by the Department of Education and the Department of Justice to recover the cost of the investigation. They can also lose access to federal student aid.
The Education and State departments began working together on foreign funding reports on Feb. 23. The State Department now helps run the federal reporting website and checks university filings for national security risks.
Duke has until mid-October to hand over the records.