The Anti-Transparency Portal: A Financial-Analytic, Data Driven Review of Obscurities, Inconsistencies and Failures of Compliance Facing Section 117 Reporting of Foreign Gifts and Donations Received by American Colleges and Universities

As mandated by congress in section 117 of the Higher Education Act, the Dept of Education receives annual reports from colleges and universities on foreign contracts and gifts totalling over $250,000. Yet withholding information on these funds, in violation of federal regulation, was widespread, until the Dept of Justice announced potential investigations. This event led to a mass disclosure in 2019-2020 with Middle Eastern and authoritarian sources comprising notable sources for funding. Worryingly, an NCRI analysis of Middle Eastern and Authoritarian funding from 117 reports provided from 2014-2019 showed significant and directional correlation with growth of antisemitism and suppression of speech in recipient campuses. These alarming trends warrant further investigation, and NCRI therefore conducted deeper, systematic, and up-to-date comparative analysis of annual Section 117 reports to better describe the total extent of funding withheld in violation of federal regulation, outline irregularities, highlight inconsistencies and illuminate other obstacles to public transparency and accountability.