Harvard quietly rewrote its screening requirements for international collaborations last month, sharply expanding when schools must check foreign researchers, visitors, students, and institutions against government watchlists.

The revised guidance, dated to August 26, is the first rewrite of Harvard’s general restricted party screening guidance in nearly a decade and comes as the federal government ratchets up its scrutiny of Harvard’s foreign ties.

The new guidance overhauls longstanding University-wide Export Controls guidance designed to govern how Harvard affiliates interact with foreign entities and ensure compliance with federal sanctions and export-control laws.

The most dramatic revision to the policy now requires screening for a far broader range of interactions between Harvard and a foreign individual or entity, whereas the 2017 guidance only listed activities that “might trigger” a screening.

As a result, the expanded policy mandates screenings in circumstances including when Harvard sponsors a foreign person for a visa, when someone pays for a foreign learner to take a hybrid or fully online course, and when foreign visitors visit “non-public areas” of Harvard.

The rewrite also makes broader restricted-party screening explicit in the general guidance, formalizes daily re-screening through Harvard’s required Visual Compliance software, and changes who decides whether a person or entity is notified after a confirmed sanctions match. The policy also broadens who may be held liable for noncompliance from just University employees to “individuals.”

When an individual is put through the screening, they are now checked against a broader set of Restricted Parties Lists — government watchlists maintained by the Departments of Commerce, State, and the Treasury. The list includes tens of thousands of entities, including universities, companies, and individuals, that may be flagged during mandated screening.

Those lists are now grouped on a matrix from “low” to “very high” risk that generally requires case-by-case assessment. The same matrix also categorizes other countries’ sanctions lists and the Australian Strategic Policy Institute’s China Defense Universities Tracker as “low to moderate risks.”

The China Defense Universities Tracker includes several universities that Harvard researchers frequently collaborate with, including Peking University, Sichuan University, and the University of Science and Technology of China. Under the new matrix, inclusion on those outside lists may be treated as a “red flag” alongside other risks.

Regardless of the outcome of an initial scan, the now-mandated Visual Compliance software retains an audit record. That system automatically re-screens searches every day and sends email alerts if a previously screened person or entity is later added to a watchlist.

The rewrite also changes who decides whether a flagged person or entity is notified. The 2017 version said an individual or entity should be notified if a recheck produced a match; the new guidance says the Office of Vice Provost of Research will determine whether to notify them and how much detail to release.

The policy edits were published nine days after the Defense Department issued an order requiring Harvard and 29 other universities to audit their foreign academic and financial partnerships. The Pentagon threatened to pull federal research funding for schools that didn’t comply.

Congressional Republicans have also long accused Harvard of maintaining inappropriate ties to China and the Chinese Communist Party. In August, the House Select Committee on the Chinese Communist Party and the House Education and Workforce Committee released a report blaming the University’s research compliance system for failing to adequately police Harvard’s ties to Chinese institutions.

The Department of Justice is separately investigating whether Harvard violated federal civil rights law by accepting China-linked gifts for financial aid programs that favor students. A Crimson analysis found that Harvard disclosed more than $36 million in gifts from sources in China and Hong Kong carrying geographic or nationality-based financial aid preferences, but only about $4 million explicitly preferred Chinese and Hong Kong sources.

Harvard spokesperson Jason Newton declined to explain why the University rewrote the guidance or whether the changes were connected to mounting federal scrutiny, instead pointing The Crimson to the University’s existing export-controls webpage.

The 2026 revisions formalize and build upon an expanded screening process Harvard rolled out August 2025 requiring University “faculty, staff, and students” to screen all international individuals attending in-person or online Harvard educational programs.

An internal presentation shared with some Economics department staff described the expanded application of the screening rules as a response to a “different focus” from the White House.

The presentation explicitly cited a School of Public Health health policy conference that drew criticism from House Republicans after officials from Xinjiang Production and Construction Corps, a Chinese organization sanctioned for human rights abuses, appeared to have attended.

Harvard is not alone among its Ivy League peers in screening foreign collaborators. Princeton University, Columbia University, Brown University, and Yale University also published restricted-party screening guidance, though the scope and mechanics differ by school.

Princeton and Columbia, for example, only “encourage” researchers to notify the universities when they are engaging with foreign entities. Yale, meanwhile, tells researchers who “have a need” to screen a collaborator to notify their director of Export Controls.

Harvard faculty members said they had not been briefed on the most recent policy changes, but mapped the move onto the University’s longer-term effort to ramp up monitoring and avoid federal scrutiny.

David Howell, a professor of Japanese history, wrote in a statement that he was concerned by the new requirement to screen what were once “utterly routine international interactions” — paying for foreign visitors or co-organizing international conferences — but said he acknowledged the legal pressure on the University.

“Although I wish there were room for discretion for interactions among historians, literature scholars and other humanists I can understand the university’s policy of erring on the side of caution,” Howell wrote.

Others said they had felt the impact of tightened guidelines long before the policy was ratified into the underlying guidelines.

“Even last year every trip abroad that I took had to be cleared first by Harvard, and the reason was that they — Harvard — in turn was worried about the government looking over their shoulders. So if it’s gotten even tougher, I think that’s too bad,” said economics professor Eric S. Maskin ’72.

Janet Gyatso, a professor at Harvard Divinity School, said the Divinity School was briefed on the screening process for paid collaborations or engagements with foreign institutions during a faculty meeting with Provost John Manning last year.

Gyatso, an affiliate of the East Asian Language and Civilizations department, said she and her colleagues were independently concerned about the University’s decision to stop accepting visiting students and scholars supported by the China Scholarship Council for a government-funded program for one-year of study at a U.S. university.

Gyatso, who works regularly with Tibetan students from China, said the prohibition was discussed during a spring department meeting and that she and others thought that it was a “big obstacle for us doing our work as scholars of China.”

“I think that we’re over-regulating ourselves just to be sure not to get into trouble with the federal government, but it is really restricting our ability to collaborate,” Gyatso said.

—Staff writer Alma T. Barak can be reached at [email protected] and on Signal at almabk.54. Follow her on X @almabk_.

—Staff writer Theresa F. Bartelme can be reached at [email protected] and on Signal at theresabartelme.15. Follow her on X @theresabartelme.

—Staff writer Hugo C. Chiasson can be reached at [email protected] or on Signal at hcc.35. Follow him on X @HugoChiassonn.

—Staff writer Elise A. Spenner can be reached at [email protected] or on Signal at elisespenner.82. Follow her on X @EliseSpenner.