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Hosting J-1 Scholars, Non-Degree and Degree Students Affiliated with Restricted Party Entities

Please see the memo below from the USC Office of Ethics and Compliance, which was shared with OIS contacts in each school on November 4, 2025:

Effective immediately, schools and units must not initiate or process initial or extension invitations for J-1 applicants affiliated with Restricted Parties, except as noted below.

Background
Recent federal actions underscore the heightened compliance obligations of U.S. universities in research involving foreign nationals. Congressional reports and federal agency guidance have documented persistent vulnerabilities in academia that enable unauthorized technology transfer to foreign adversaries. The Department of War (Department of Defense – DoD) now prohibits funding for collaborations with institutions on the Section 1286 List and requires mitigation or rejection of research involving any such affiliation.

Definition of Restricted Parties
Restricted Parties are those institutions designated by the Office of Ethics and Compliance (OEC) and generally include any entities appearing on the DoD Section 1286 List, the DoD 1260H List, or designated by OEC as Other High-Risk Institutions. These entities are identified by the U.S. government as presenting significant national security or research integrity risks due to affiliations with foreign defense or intelligence apparatuses.

Required Action by Academic Units, Schools and HR Partners

  • Prior to initiating any J-1 appointment, confirm whether the scholar’s current or prior institutional affiliations appear on any Restricted Party list.
  • Do not extend initial or extension invitations to J-1 Scholars affiliated with any entity on one of the Restricted Party lists.
  • For any extension applications already in process as of the date of this memo, a one-time, one-year extension may be approved through the Office of International Services. Please note: future extension/renewal requests will be denied.
  • When uncertain about an institution’s status or affiliation (including potential dual appointments or prior graduate study at restricted institutions), consult with OEC before proceeding.
  • Units must maintain documentation of affiliation screening in appointment files for audit purposes.

Questions?
If you have any questions regarding specific scenarios, please contact the Office of Ethics and Compliance.