The new list includes 130 higher education and research institutions across China, Russia, and Iran identified as engaging in "problematic activities."
Among these, 88 institutions are located in China. In addition to entities previously subject to restrictions, prominent Chinese universities—such as Fudan University, Shanghai Jiao Tong University, and Shandong University—were included for the first time.
The Department of War stated that these entities participated in activities that risk exposing federally funded research to foreign governments, threatening U.S. national security and scientific integrity.
The policy establishes primary restrictions on cross-border academic engagement. Beginning in FY2026, strict funding bans will prohibit U.S. universities and research entities from using Department of War funds to conduct joint research or share equipment with any listed institutions.
Researchers who continue collaborating with personnel affiliated with the designated entities risk compromising their own eligibility to secure future federal research funding.
Furthermore, researchers must fully report any formal relationships with listed institutions as well as any participation in foreign talent recruitment programs, with non-disclosure carrying severe legal penalties under federal law.
Stricter Security Reviews
Experts noted that while previous U.S. restrictions focused primarily on universities with direct ties to the Chinese military, this update expands the scope of research security reviews to include more comprehensive, civilian research universities.He added that while the CCP previously utilized various avenues to import or absorb U.S. technology, these channels are now being closed one by one, dealing a severe blow to China's "overtaking on the curve" strategy.
"China continually emphasizes self-reliant development, yet it lacks the fundamental science or technical foundation to do so independently; it has relied heavily on imitation or 'overtaking on the curve.' As restrictions and sanctions increase, its capacity to leapfrog will diminish, significantly constraining its technological advancement," he said.
Heng He, a U.S.-based political commentator, said that the United States is gaining a clearer understanding of the role ordinary (or civilian) Chinese universities play in the CCP’s military-industrial development.
"Strictly speaking, there are no real civilian universities in China. They are all controlled by the CCP and overseen by the Ministry of Education. Whenever the CCP requires data or resources, these universities step up—unlike in other countries where academic and military sectors are distinct."
Heng argued that, unlike Russia, the CCP lacks a fully independent technological ecosystem and has historically relied on imitating the United States, particularly in cutting-edge fields.
"Since the reform and opening-up era, the CCP has consistently followed the United States. No matter how it develops, it is constantly striving to catch up with the U.S., targeting existing American advances as milestones to surpass," he said.
He concluded that if tech ties with the U.S. are severed or restricted, China's research and development will face severe obstacles, significantly impacting its military industry, advanced technology, and AI development.
