The federal register of foreign money in American universities has one governing fact, and it is not a dollar figure. Computed from the ledger: 97.1 percent of every disclosed dollar carries no source name. Not because institutions hid it — because Section 117 of the Higher Education Act never asks.
What the form wants
For an ordinary foreign gift or contract above the $250,000 threshold, the statute requires three things: the amount, the date, and the country of the source, plus a flag for whether that source is a foreign government. That is the whole record. So China's $4.06B across 6,818 transactions resolves, in nearly every row, to the phrase “a foreign source in China.” Which university, which year, how much — all there. Which company, foundation, ministry, or person — not collected. The exception is the restricted-transaction category, where foreign government sources are named; that is why the only named entities in the entire file read like a diplomatic directory, and why they cover just 2.9 percent of the money.
Disclosure follows enforcement, not money
The biggest year in the record is 2019: 7,572 disclosures for $4.15B. That was not the year foreign money peaked — it was the year the Department of Education opened compliance investigations into a dozen elite institutions, and decades of unreported transactions surfaced at once. By 2023 the annual count had fallen to 2,285. A disclosure regime's output tracks the pressure applied to it — the ledger measures compliance behavior as much as capital flows, and says so on every page.
The fight over fixing it
Congress has a live answer on the table. The DETERRENT Act passed the House 241–169 in March 2025: it would drop the general threshold from $250,000 to $50,000, set it to zero for countries of concern, restrict contracts with those countries absent a waiver, and — the part this ledger makes vivid — require far more of the money to carry an identity. As of this file's vintage the bill sits in the Senate committee process, with universities' associations opposed on academic-freedom grounds and advocacy coalitions pressing for passage; the Department has meanwhile tightened administration of the existing rule. Whatever the outcome, the terms of the argument are computable: opponents and supporters are fighting over whether 97.1 percent anonymity is a bug or a boundary.
The honest finding
Nothing in the ledger shows evasion of Section 117's naming requirements, because for most of the file there are none to evade. The law worked exactly as written for forty-five years, and what it produced is a record whose most important fact is what it does not contain. That is worth knowing before citing the totals — ours included.
Method
All shares computed live from the Section 117 Ledger (Department of Education cumulative public file, public domain; aggregate-only, no personal data). Legislative status per the Congressional Research Service summary linked above; characterizations of support and opposition are attributed to the organizations that published them. No wrongdoing is asserted of any institution or source — anonymity here is statutory design.
The data: Section 117 Ledger — keyless JSON, CC0, named-source share computable from restrictedGovernmentSources.
Related writing: Sixty-Two Billion Dollars — the full reading of the ledger.
Related writing: The Shell Game in the Farmland Register — the same lesson from the land register: a disclosure regime reveals exactly what its form fields ask.