Sensitive Research & Anti-Money Laundering: a Possible Marriage of Convenience?

Sensitive Research and Anti‑Money Laundering: Could AML Tools Protect University Science?

Universities have become prime targets for foreign intelligence and state-directed technology acquisition. Their openness, interdisciplinary collaborations, and global student and staff mobility make them fertile ground for actors seeking novel technologies, dual‑use capabilities, or intellectual property. Cases of alleged theft, recruitment of insiders, and covert influence show the scale of the threat: compromised projects can accelerate foreign military or commercial capability, erode public trust, and put researchers at legal and personal risk. Governments have begun to respond with export controls, foreign activity reporting, and tailored research‑security policies, yet implementation across higher education remains inconsistent. Many institutions are under‑resourced and worry that heavy‑handed controls will damage academic freedom, collaboration, and funding flows. The central policy challenge is therefore to reduce the security risk without suffocating the knowledge ecosystem that universities exist to sustain.

What anti‑money laundering regimes offer: principles that map to research security

Anti‑money laundering and counter‑terrorism finance systems were built to make illicit flows visible, to nudge private actors toward risk‑aware behavior, and to coordinate intelligence across public and private sectors. Key features include registration and oversight of regulated entities, risk‑based compliance programs, customer due diligence and enhanced scrutiny of high‑risk actors, transaction monitoring and suspicious‑activity reporting, and public‑private information sharing partnerships subject to confidentiality protections.

Those tools were not designed for research security, but they show several structural strengths relevant to universities:

• a risk‑based, scalable approach;
• a mix of internal compliance and external supervision;
• incentives for reporting and coordination; and
• legal architectures that protect sensitive reports from misuse.

Adapting these features could allow universities to detect and manage risks from covert funding, problematic collaborations, and insider exploitation while preserving legitimate research exchange.

Bastian Schwind-Wagner_Follow "Adapting anti‑money laundering principles to research security offers a practical, risk‑based way for universities to detect covert funding and foreign interference while preserving legitimate academic collaboration. Carefully designed legal safeguards and proportional implementation are essential to protect researcher rights and maintain openness."

A proposed research‑security framework adapted from AML practices

Registration and baseline obligations: Each university should register with a designated national research‑security regulator and maintain a proportionate institutional research‑security program. That program would be risk‑based, tailored to the institution’s size and research footprint, and reviewed periodically. Core elements would include executive oversight, a named research‑security compliance officer, documented procedures, and mandatory staff and student training on threat indicators and reporting obligations.

Know‑your‑partner and funding diligence: Adapting Know‑Your‑Customer concepts, universities would adopt due‑diligence processes for research partners, donors, and funding sources. Verification would scale with risk: routine checks for low‑risk grants and deeper, documented scrutiny for foreign government‑linked entities, donations tied to specific technical outcomes, or partners from jurisdictions flagged for undue influence. Use‑of‑funds and project end‑use assessments would be standard for high‑value or dual‑use projects.

Enhanced scrutiny for high‑risk actors and activities: Introduce the concept of politically exposed researchers (PERs) and high‑risk projects (e.g., classified work, certain dual‑use domains, or projects with sensitive defence implications). When PERs or high‑risk collaborations are involved, institutions would trigger enhanced due diligence: deeper provenance checks, periodic reviews, contractual safeguards, and, where necessary, restrictions on data export or personnel access.

Transaction monitoring and reporting: Financial flows linked to research — grants, donations, contractor payments, and large international student fees — would be subject to monitoring systems that flag unusual patterns, including
rapid, unexplained increases in funding, routing through opaque intermediaries, or conditions that limit publishability or independent verification. Suspicious cases would be reported to the regulator through confidential research‑security reports, mirroring suspicious‑activity reports in AML systems and protected by strict legal confidentiality to encourage reporting.

Internal screening and personnel risk management: Institutions would deploy proportionate personnel‑risk measures focused on roles with material access to sensitive information or facilities. These would be framed around functional risk (access and privileges) rather than nationality. Checks could include enhanced onboarding vetting for designated roles, periodic re‑assessments for those with sustained privileged access, and targeted counter‑intelligence awareness — implemented with privacy safeguards and appeal mechanisms to protect personal rights as much as possible.

Information sharing via a research‑security alliance: Create a government‑facilitated public‑private partnership akin to financial sector alliances, enabling trusted, reciprocal intelligence sharing between universities, funding bodies, national research agencies, and security services. Such an alliance would issue timely threat advisories, enable anonymized indicators of compromise across institutions, and coordinate responses to cross‑institutional campaigns without undermining academic confidentiality.

Oversight, evaluations, and proportionality: Implement periodic peer or regulator evaluations to measure institutional compliance and effectiveness, modelled on mutual evaluation principles but tailored to academic contexts. Evaluations should incorporate impact assessment to avoid overbroad measures that harm collaboration or marginalize legitimate research. The regulatory model must emphasize proportionality, controls should address demonstrable risk and preserve legitimate scholarly exchange.

Legal and ethical safeguards to protect academic freedom and privacy

Any adaptation of AML techniques to research security must explicitly guard core civil liberties and academic norms. Confidential reporting channels and legal protections should ensure that reports are not used as evidence in unrelated legal proceedings and cannot be compelled in ways that damage research trust. Due diligence and screening must be directed by role‑based risk, not by nationality alone, and include independent appeal pathways for researchers who consider themselves unfairly targeted. Privacy laws must be reconciled with sharing needs, with narrow, statutory gateways for necessary intelligence exchange and limits on retention and reuse of sensitive data.

Practical challenges and limits to expect

Translating AML methods to universities is not a straight swap. Implementation carries cost: staffing, technology, compliance overhead and training. Small institutions will need scaled approaches and public funding to avoid leaving them exposed. Like AML, research‑security programs risk over‑reporting, bureaucratic burden, and uneven application across institutions that could encourage regulatory arbitrage. There is also a real policy trade‑off: excessively restrictive regimes may drive researchers away, reduce openness, and harm scientific progress. Finally, governance must manage conflicts between institutional reputational incentives and the public interest in disclosure; legal confidentiality for reports and regulatory oversight can help realign incentives.

Policy recommendations for a workable start

Governments should establish a dedicated research‑security regulator or assign clear statutory responsibility to an existing body, with powers to register institutions, receive protected reports, and produce sector guidance. That regulator must be jointly staffed by capable security analysts and subject‑matter specialists. Policymakers should pilot a risk‑tiered program: basic registration and training for all institutions, enhanced obligations only for those engaged in designated high‑risk domains, and subsidized compliance support for smaller universities. A national research‑security alliance should be stood up to facilitate timely threat sharing and best‑practice dissemination. Finally, statutory safeguards around confidentiality, non‑discrimination, and appeals must be embedded from the outset to preserve academic freedom and researcher rights.

Conclusion: an approach that balances security and scholarship

Drawing appropriate lessons from AML systems can yield pragmatic, scalable measures that help universities identify foreign interference, protect sensitive research, and coordinate with national security partners. The central objective should be to create a risk‑based, intelligence‑informed framework that reinforces openness where safe, restricts risky pathways where necessary, and preserves the ethical and legal protections central to academic life. Careful design, resourcing, and legal safeguards are essential: if done well, a calibrated research‑security regime can reduce exploitative threats while sustaining the collaborative nature of scientific research.

Dive deeper

• Research ¦ Walker-Munro, B., Ferrill, J., & Tiwari, M. (2025). Sensitive research & anti-money laundering: a possible marriage of convenience? Current Issues in Criminal Justice, 37(2), 308–333. https://doi.org/10.1080/10345329.2025.2467483 ¦ Link ¦ licensed under the following terms, with no changes made: CC BY-NC-ND