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Harvard will begin screening international participants, faculty, and co-sponsors for all University-affiliated educational events — including executive education programs, online programs, workshops, and conferences — according to an internal presentation obtained by The Crimson.

The slide deck, which was presented to some Economics Department staff on Oct. 30, detailed expanded compliance measures that require screenings for international attendees and collaborators of Harvard educational programs from certain restricted countries, including China, Iran, and Russia.

It also noted that some activities, including the sharing of research materials, allowing access to research spaces by international visitors, or presenting unpublished research abroad, may require export licenses in coordination with federal agencies.

While the University officials explained in the slides that export control laws have long applied to international collaborations, the presentation attributed the new blanket policy — which had historically only applied to high-profile science and technology endeavors — to a “different focus” from the Trump administration and inquiries from the House Republicans into Harvard’s activities overseas.

“This has always been the law and a requirement. However, past federal administrations have focused on materials and transactions related to high technology, military and dual-use applications, STEM, Biotech, Medicine, etc.,” the slides read. “This current administration has a different focus and all collaborations and work with foreign entities are being scrutinized.”

A Harvard spokesperson wrote in a statement that the new screening procedure was part of the University’s commitment to “complying with U.S. sanctions and export controls.”

“Harvard has developed — and continues to adapt and strengthen — its sanctions and export control policies and procedures to meet the evolving national security risk environment and regulatory requirements,” they wrote.

Under the new procedure, Harvard affiliates hosting in-person educational programs with international attendees will have to submit participants’ names, affiliations, and nationalities in addition to the purpose of the events and content being shared to a small Harvard team responsible for screening and approving participants. The screening will not apply to programming that is free and open to the public without prior registration.

A plan to screen all international participants in Harvard-affiliated online educational programs prior to receipt of payment is currently under discussion with top Harvard officials, according to a note included in the slides.

The presentation cited a House Select Committee on the Chinese Communist Party investigation into a health policy conference at the Harvard School of Public Health, which they claimed was attended by members of the Xinjiang Production and Constructions Corp, as a motivating factor for the new procedures. (The XPCC is a CCP-affiliated paramilitary organization that has been sanctioned by the U.S. government over its involvement in the detention of Uyghurs in Xinjiang.)

An archived version of HSPH’s website listed the XPCC as a participant in a 2019 conference that was a part of the school’s “Training Course on Health Financing,” but that listing has since been removed. According to the conference’s website, XPCC officials were present again in 2023 and 2024 — years after the group was sanctioned by the U.S.

The Trump administration has hinged its accusations against Harvard of illegally partnering with China on XPCC’s involvement in the conference after it was officially sanctioned. In June, Secretary of State Marco Rubio urged the Treasury Department to open an investigation into whether Harvard violated sanctions law by cosponsoring the conference.

The administration turned its eyes to the conference after a report — which was funded by the conservative Manhattan Institute and published by Strategy Risks, a corporate intelligence firm — detailed Harvard’s involvement in the conference.

Isaac Stone Fish, the CEO of Strategy Risks, called Harvard’s decision to institute a blanket screening of international participants, including those from China, a “smart one” in an emailed statement.

“One imagines that the Trump administration’s pressure played a role, but also hopefully the recognition from the changing geopolitical landscape that Harvard needs to be smarter about understanding, managing, and reducing its China risks,” he wrote.

Under the new procedure, Harvard will use Visual Compliance — a platform that crosschecks names against government watchlists — to screen participants and organizations from abroad for ties to sanctioned countries or restricted entities. The slide deck noted that additional approval is needed for countries designated by the U.S. government as “Countries of Concern” including China, Iran, and Russia, as well as “High Cyber Risk Regions” such as Hong Kong, Cuba, and Sudan.

Parts of the new screening policy are available on the Office of Vice Provost and Research’s website with the tag “NEW,” but the reasoning for the change is explicitly detailed only in the slides presented to some FAS affiliates last week.

While the screening process is new at Harvard, other schools such as the University of Pennsylvania and the Massachusetts Institute of Technology have had similar processes in place for years. Immigration attorney Dahlia M. French wrote in a statement that she was surprised that Harvard had not previously instituted the export control policies for educational programs.

“To be honest, I’m a bit surprised to learn that a highly competitive school like Harvard isn’t doing this already,” she wrote.

​​—Staff writer Dhruv T. Patel can be reached at dhruv.patel@thecrimson.com. Follow him on X @dhruvtkpatel.

—Staff writer Saketh Sundar can be reached at saketh.sundar@thecrimson.com. Follow him on X @saketh_sundar.