Executive Summary

Despite clear congressional intent outlined in Section 1260H of the 2021 National Defense Authorization Act (NDAA), U.S. Department of Defense (DoD) funding continues to flow to Chinese Military Companies (CMCs)—entities formally designated by the U.S. government as threats to national security. This persistent failure of oversight has enabled at least $48 million in DoD-funded research to directly or indirectly benefit Chinese military-linked firms, including Huawei, BGI, China General Nuclear Power Group, and China Mobile—core components of China’s military-industrial complex. Although current DoD policy requires mitigation for affiliations with entities listed under Section 1260H of the FY2021 NDAA and Section 1286 of the FY2019 NDAA, these measures have proven insufficient. Mitigation protocols have failed to stop adversarial access to sensitive U.S. defense research. Mitigation measures are discretionary, informal, and inconsistently applied. While the law identifies risk, it does not mandate how that risk must be addressed—leaving enforcement up to individual program officers and research institutions, with no mandatory prohibition mechanism in place. The continued presence of Chinese Military Companies in DoD-funded academic collaborations reveals not only the inadequacy of existing safeguards—but the urgent need for a categorical prohibition on all such engagements.

Findings: U.S. DoD Funds Supporting Chinese Military Companies

A review of federally funded academic and scientific research has identified seventeen specific cases in which Chinese Military Companies participated in or benefited from DoD-funded research. These cases involve top U.S. research institutions—including the Massachusetts Institute of Technology (MIT), Virginia Polytechnic Institute & State University, University of California Santa Cruz, Washington University, Vanderbilt University, Yale University, and Princeton University—engaged in partnerships with Chinese military-linked firms on projects directly funded by the DoD. DoD’s current policy guidance—codified in its internal decision matrix—identifies affiliations with Section 1260H and Section 1286 entities as research security risks requiring mitigation. However, this approach places the burden on individual program officers and research institutions to interpret risk, rather than enforcing a clear prohibition. This has led to inconsistent application, delayed interventions, and continued access by adversarial entities.