Enhancing National Security by Addressing Risks at Harvard University

6/4/2025

Proclamations

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Action Summary

Authority and Purpose: President Trump invokes sections 212(f) and 215(a) of the Immigration and Nationality Act to restrict entry of foreign students and exchange visitors at Harvard University due to national security concerns.
Risk Identification: Harvard University is accused of failing to comply with federal requirements by not providing sufficient disciplinary and criminal records for foreign students, thereby undermining the integrity of the Student Exchange Visa Program (SEVP) and national security.
Concerns Over Foreign Influence: The proclamation cites Harvard’s extensive financial ties with foreign governments, including over $150 million from China in the past decade, and partnerships that may support adversarial advancements, such as military modernization.
Campus Safety and Disciplinary Issues: Rising crime rates and inadequate disciplinary measures at Harvard are highlighted as factors that compromise the safety and legal compliance of the campus environment.
Discriminatory Admissions and Civil Rights: Harvard is accused of continuing discriminatory admissions practices that hinder equal opportunities for American students while favoring students from countries considered non-egalitarian or adversarial.
Implementation of Suspension:
- Scope: The entry of any alien entering under F, M, or J visas solely to study at or participate in an exchange program at Harvard is suspended for six months.
- Exemptions: The suspension does not apply to students at other institutions or to individuals whose entry is determined to be in the national interest.
- Revocation Risk: Current foreign students at Harvard could have their visas revoked at the discretion of the Secretary of State.
Administrative and Coordinated Actions: The Secretary of State, Attorney General, and Secretary of Homeland Security are tasked to coordinate implementation, including evaluating potential restrictions on Harvard’s eligibility to participate in SEVP and the Student and Exchange Visitor Information System.
Review and Extension Provisions: A joint recommendation on the further extension of these restrictions is to be submitted within 90 days by the Attorney General and the Secretary of Homeland Security.

Risks & Considerations

The Executive Order highlights the importance of compliance with federal regulations concerning foreign students, emphasizing national security concerns. Vanderbilt University must ensure strict adherence to these regulations to avoid similar scrutiny and potential restrictions.
There is a risk that increased federal oversight and potential restrictions on foreign students could impact Vanderbilt’s ability to attract international talent, which is crucial for maintaining a diverse and vibrant academic community.
The focus on national security and compliance may require Vanderbilt to enhance its record-keeping and reporting practices regarding foreign students, potentially increasing administrative burdens and costs.
Vanderbilt may need to review its partnerships and collaborations with foreign entities to ensure they do not pose a risk to national security or violate federal regulations.

Impacted Programs

International Student and Scholar Services (ISSS) at Vanderbilt may need to implement more rigorous procedures for monitoring and reporting on foreign students to comply with federal requirements.
Office of the General Counsel might need to provide additional legal guidance to ensure that the university’s policies and practices align with federal regulations concerning foreign students and national security.
The Office of Global Safety and Security could play a crucial role in assessing and mitigating risks associated with international collaborations and partnerships.
Vanderbilt’s research programs, particularly those involving sensitive or dual-use technologies, may require additional oversight to prevent unauthorized access or information sharing.

Financial Impact

Potential restrictions on foreign students could lead to a decrease in international student enrollment, impacting tuition revenue and the financial health of the university.
Increased administrative and compliance costs may arise from the need to enhance record-keeping, reporting, and security measures related to foreign students and international collaborations.
Vanderbilt may need to invest in additional resources and personnel to ensure compliance with federal regulations and to manage the potential impacts of increased federal oversight.
Opportunities for federal funding and grants may be affected if Vanderbilt is perceived as non-compliant with national security-related regulations, necessitating careful management of compliance and reporting practices.

Relevance Score: 4 (The order presents a need for potential major changes or transformations of programs.)

Key Actions

Office of International Student and Scholar Services should ensure full compliance with SEVP regulations by maintaining accurate and comprehensive records of foreign students, including any disciplinary actions. This will help Vanderbilt avoid similar scrutiny and potential restrictions as faced by Harvard University.
Office of Federal Relations should engage with federal agencies to understand any new compliance requirements or expectations regarding foreign student programs. Proactively addressing these requirements can safeguard Vanderbilt’s participation in international student exchange programs.
Vanderbilt’s Legal Affairs Office should review and update policies related to foreign collaborations and funding to ensure transparency and compliance with federal regulations. This will mitigate risks associated with foreign entanglements and maintain the university’s reputation.
Department of Political Science should conduct research on the implications of foreign student restrictions on national security and higher education. This research can provide valuable insights and position Vanderbilt as a thought leader in policy discussions.
Vanderbilt’s Admissions Office should assess the potential impact of foreign student restrictions on enrollment and diversity. Developing strategies to attract and support a diverse student body will be essential in maintaining the university’s global standing.

Opportunities

The executive order presents an opportunity for Vanderbilt’s Center for International Studies to expand its research on the role of international students in higher education and national security. By contributing to this discourse, the center can enhance its influence and attract funding for related projects.
Vanderbilt can capitalize on the increased scrutiny of foreign collaborations by strengthening partnerships with domestic institutions and government agencies. This could include joint research initiatives and policy development, enhancing Vanderbilt’s reputation and reach in the academic and policy sectors.
The focus on national security offers an opportunity for Vanderbilt’s School of Engineering to develop programs and research initiatives that address cybersecurity and information protection. By aligning with national priorities, the school can secure funding and partnerships that support its growth and innovation.

Relevance Score: 4 (The order necessitates major process changes to ensure compliance and mitigate risks associated with foreign student programs and collaborations.)

Average Relevance Score: 3.4

Timeline for Implementation

Suspension of Entry: This directive expires 6 months (approximately 180 days) after the proclamation date.
Recommendation Submission: The Attorney General and the Secretary of Homeland Security must submit a recommendation within 90 days from the proclamation date.

The shortest timeline is 90 days, which places the urgency level within 90-179 days to comply.

Relevance Score: 2

Impacted Government Organizations

Department of Homeland Security (DHS): Responsible for overseeing the Student Exchange Visa Program (SEVP), collecting required disciplinary and criminal records from academic institutions, and ensuring that foreign nationals comply with federal law.
Department of State: Charged with evaluating whether to revoke visas of current foreign students at Harvard University and determining exceptions based on national interest criteria.
Department of Justice (Attorney General’s Office): Tasked with coordinating with DHS to review the situation at Harvard and to submit recommendations regarding the extension or renewal of the entry suspension.
Office of Management and Budget (OMB): Mentioned in the general provisions to ensure that the proclamation’s implementation is consistent with budgetary and administrative guidelines.

Relevance Score: 2 (Between 3 and 5 federal agencies are directly impacted by the measures outlined in this presidential proclamation.)

Responsible Officials

Secretary of State – Responsible for considering visa revocations, overseeing the suspension’s scope, and coordinating with other agencies.
Attorney General – Charged with joint submission of recommendations regarding the suspension and ensuring enforcement through legal avenues.
Secretary of Homeland Security – Tasked with participating in the coordination to implement the suspension and ensuring compliance with national security requirements.

Relevance Score: 5 (Directives affect Cabinet-level officials responsible for national security and immigration policy execution.)