Arms Control and International Security Papers 

Volume 11 Number 9 

June 5, 2020 

Technology Transfers to the 

PRC Military and U.S. 

Countermeasures: 

Responding to Security 

Threats with New 

Presidential Proclamation 

by Christopher A. Ford 

The Arms Control and International Security Papers are produced by the Office of the Under Secretary of State for Arms Control 

and International Security in order to make U.S. State Department policy analysis available in an electronically-accessible 

format compatible with "social distancing" during the COVID-19 crisis. 
 

Arms Control and International Security Papers 

Technology Transfers to the PRC Military and U.S. Countermeasures: 

Responding to Security Threats with New Presidential Proclamation 

Volume I, Number 9 I June 5, 2020 

Technology Transfers to the PRC Military and U.S. 

Countermeasures: Responding to Security Threats 

with New Presidential Proclamation 

by Christopher A. Ford1 

In this addition to the AC/5 Papers, Assistant Secretary Ford outlines the 

changes the United States recently announced to rules pertaining to the entry 

of certain students and researchers from the People's Republic of China in 

response to the national security challenges presented by Beijing's Military-Civil 

Fusion strategy. 

On May 29, 2020, the United States announced _g_ 

significant new change in its approach to granting visas to 

certain applicants from the People's Republic of China 

(PRC) who wish to study or conduct research in fields that 

the United States determines would contribute to Beijing's 

Military-Civil Fusion (MCF) strategy. Much as we 

attempted to do with the detailed explanation of our 

recent national security export control license changes visa-vis the PRC telecommunications company Huawei that 

was published as an AC/5 Paper on May 22, this latest paper 

will not only describe these new adjustments to U.S. visa 

policy, but also 

"situate them in the full context in which they need to 

be understood - specifically. as part of an ongoing U.S. 

effort to respond to the challenges that have 

unfortunately been created by the PRC's manipulation 

and exploitation of China-based entities (and Chinese 

citizens) in support of the Chinese Communist Party's 

(CCP's) efforts to remain in power in the PRC and to 

seize for itself the commanding heights of military and 

technological power in the mid-21st-Century 

geopolitical arena." 

I. The MCF Challenge 

Readers of this AC/5 Papers series - and indeed anyone 

who has been following the work of the U.S. State 

Department's Bureau of International Security and 

Non proliferation over the last two years -will by now need 

no reminding of the degree to which we in the United 

States Government have awakened to the threats 

presented to U.S. security by the PRC's MCF strategy. This 

awakening represents a recognition of the reality with 

which Beijing has confronted us, coupled with a 

determination to respond robustly to protect U.S. interests, 

as well as the interests of free, democratic peoples 

everywhere who are (or will be) menaced by the PRC's 

growing and increasingly provocative and destabilizing 

actions. Working together with key agencies, we have 

been making significant changes to our policies and 

approaches in light of this new understanding. 

1 Dr. Ford serves as U.S. Assistant Secretary of State for International Security and Non proliferation, and is additionally peiforming the Duties of 

the Under Secretary for Arms Control and International Security. He previously served as Special Assistant to the President and Senior Director 

for Weapons of Mass Destruction and Counterproliferation on the U.S. National Security Council staff 
Arms Control and International Security Papers 

Technology Transfers to the PRC Military and U.S. Countermeasures: 

Responding to Security Threats with New Presidential Proclamation 

We take MCF seriously because the PRC takes it 

seriously. MCF is a national-level strategy that General 

Secretary Xi Jin ping personally oversees. While most 

countries observe norms that prevent diversion of dual-use 

and civilian technologies to military ends - at least not, at 

any rate, without permission from the technologyoriginator-the PRC does not. Through MCF, the PRC has 

been deliberately eliminating the barriers between its 

defense industrial complex and the civilian economy. In 

effect, any technology available to anyone under PRC 

jurisdiction, anywhere, can be diverted to support the 

People's Liberation Army (PLA) and the PRC security 

services in support of the CCP's domestic, regional, and 

global ambitions. And, increasingly, it will be. 

MCF's technology-acquisition and -diversion strategy 

is of cardinal importance to the CCP, moreover, for 

strategic and geopolitical reasons that should be of 

enormous concern to all of us in the world's free and 

autonomous democracies. The PRC hopes and expects by 

such means to position itself on the leading edge of the 

next "revolution in military affairs" (RMA), which it assumes 

will give it the keys to mid-21st Century geopolitical power 

just as countries at the forefront of history's several prior 

RMAs were able to use the resulting military-technological 

advantages to dominate the world-systems of their own 

eras. As we at the Department of State have warned 

repeatedly, technology acquisition is a central plank of the 

CCP's blueprint for China's global "return" to military 

preeminence. and has the ultimate aim of achieving the 

CCP's dream of seizing the leading role in world affairs by 

the 2049 centenary of the founding of the People's 

Republic of China. 

I have been drawing attention to these challenges 

since July 2018. Most obviously, this MCF challenge 

represents a significant and direct national security threat 

to the United States, as well as to the many other countries 

that have been reacting with understandable alarm as 

Beijing has thrown to the winds Deng Xiaoping's "hide-andbide" policy of strategic caution and has instead set out 

upon an increasingly aggressive, destabilizing, and 

provocative path in international relations - for the first 

time in a generation outwardly expressing (and acting 

upon) the strategic goals and intentions Deng had 

cautioned them to "hide." 

But MCF also presents a policymaking challenge of 

balance, for even while we must answer these security 

threats with robust and vigorous responses, we must also 

still work to preserve the possibility of cooperation with the 

Volume I, Number 9 I June 5, 2020 

PRC. Our two countries are too big, too powerful, and too 

enmeshed in reciprocal economic dependencies for a purely 

adversarial approach to make sense; our challenge as 

policymakers is to know where to draw the line. As I told a 

conference in March 2019: 

" ... [O]ur biggest challenge in dealing with China is 

that our relationship with Beijing has both competitive 

and cooperative aspects - aspects that we somehow 

have to manage at the same time. and for which our 

more purely adversarial Cold War experiences with the 

Soviet Union do not provide a very useful conceptual 

template. Our competitive mindset needs to keep us 

focused upon competing vigorously and effectively. 

but never without consideration of our two countries' 

mutual economic entanglement and the dangers and 

opportunities that this creates in the Sino-American 

relationship. Doing this well will be far from easy." 

Given the centrality of foreign technology acquisition 

to the PRC's "Military-Civil Fusion" strategy- and the ways 

in which MCF's deliberate erasure of distinctions between 

"civilian" and "military" problematizes many traditional 

Western approaches to threat mitigation -this challenge is 

particularly acute in the arenas of national security export 

control implementation and visa screening. There, as 

elsewhere, we need always to be asking ourselves: 

"To what extent can we pursue such cooperation 

without providing China with technological tools that 

will help it achieve its goal of seizing a geopolitical role 

for itself that displaces U.S. influence? ... How we 

balance the potential benefits from ... engagement 

with China against the considerable national security 

risks that now clearly exist from that very same 

engagement will require careful thought .... " 

Unfortunately, however, providing a sound answer to 

this question has required us to recalibrate some of our 

approaches in light of the PRC's relentless emphasis upon 

MCF and its targeting of U.S. and other foreign 

technologies for both licit and illicit acquisition. As 

Secretary of State Pompeo made clear in a recent speech in 

Silicon Valley. the United States now takes these 

challenges very seriously, and we have been gradually 

reorienting the U.S. foreign policy and national security 

apparatus around the challenges of meeting this threat. 

Our objective is to balance the long-standing values 

that have contributed to our success as a global leader in 

cutting-edge research with the security requirements we 

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Arms Control and International Security Papers 

Technology Transfers to the PRC Military and U.S. Countermeasures: 

Responding to Security Threats with New Presidential Proclamation 

now face in light of the way in which PRC policy has placed 

the previous equilibrium in jeopardy. Even as we seek to 

preserve the integrity of an open and transparent academic 

system that attracts the most qualified candidates from 

around the world, regardless of nationality, to our 

outstanding educational and research institutions, we must 

act to prevent this system from being exploited for the 

benefit of our strategic competitors. 

II. Technology Transfer Threats from Co-Opted 

Students and Researchers 

I have commented at length publicly on other aspects 

of this U.S. recalibration, from changes we have made in 

U.S. regulations governing exports of civil-nuclear 

technology to adjustments to our export regulations 

concerning the PRC telecommunications company Huawei. 

The most recent U.S. adjustments of approach concern visa 

and entry policy, but it is worth emphasizing that even this 

is hardly a new issue. It has been clear for some time that 

recalibration was necessary here as well. 

As I pointed out as early as September 2018, as we 

build global "coalitions of caution" with the increasing 

number of likeminded international partners who 

understand, and who are seeking to coordinate improved 

responses to, PRC technology-transfer threats, greater 

attention needs to be paid to the issue of "deemed exports" 

or "intangible technology transfer (ITT)" -that is, the less 

concrete and often inadvertent transfers of technology that 

can occur through engagements, as perhaps simple as an 

ordinary conversation, with students or researchers. While 

these knowledge exchanges are fundamental to academic 

and research collaborations in a Western university, 

laboratory, or technology company, such transfers of 

technology- of the "know how" or the "know why" of 

cutting-edge science and its applications - are also 

precisely what MCF seeks in its attempts to mine and 

exploit our open knowledge system to support the 

strategic objectives of the Chinese Communist Party (CCP). 

Information can be transferred in a variety of ways, of 

course, including through both physical (tangible) and nonphysical (intangible) means. Awareness of this makes 

placing at least some visibility into and check upon such 

adventitious transfers just as important as are the explicit 

national security export controls that responsible nations 

have long - and with good reason - placed upon specific 

items themselves. MCF seeks to use such engagements for 

the benefit of the PRC's military and security services, 

taking advantage of the enormous leverage the PRC 

Volume I, Number 9 I June 5, 2020 

system has over its students and researchers traveling 

abroad in service of state technology-acquisition 

objectives. And we shouldn't help them. 

It is worth remembering that, in sharp contrast to the 

situation in Western countries, any part of the technology 

sector in the PRC can be compelled to cooperate with state 

authorities. The PRC's 2017 National Intelligence Law, for 

instance, requires all citizens and organizations to support, 

assist, and cooperate with national intelligence agencies 

and efforts. (Nor, of course, is that the only way in which 

the PRC can compel citizens abroad to serve its interests. 

In the police state that is the People's Republic of China, 

the Party has enormous reservoirs of coercive power upon 

which it can rely in forcing even the most well-meaning 

traveler to cooperate with authorities back home, or to 

penalize him if he does not.) The PRC obliges its citizens to 

participate in these strategies, and has devoted significant 

state financing to develop its national defense science and 

technology ecosystem, which under MCF incorporates 

civilian researchers and academics into defense R&D 

efforts in ways that are often both compulsory and 

intentionally concealed. MCF, in other words, deliberately 

sets out to capitalize on the West's traditional global ethos 

of free scientific and educational exchange, weaponizing 

that ethos in support of Beijing's destabilizing geopolitical 

revision ism. 

Nor does the PRC hide this ambitious effort. In China 

itself, the 13th Five Year Plan for Military-Civil Fusion 

Science and Technology Development explicitly calls for 

establishing collaboration with universities and research 

institutions in foreign countries that possess advanced 

technology. This is done, in part, to acquire that 

technology and bring it back to the PRC. Under MCF, the 

CCP is working to systematically reorganize the science 

and technology enterprise to ensure that new innovations 

simultaneously advance economic and military 

development. This ambitious endeavor relies significantly 

on the Chinese university system to develop the 

capabilities to undertake world class R&D and innovation. 

At present, the PRC has as many as 100 specific statedirected plans that govern when and how to undertake 

such foreign technology acquisition work. Since 2009, 

moreover, more than 150 Chinese universities have 

received special security credentials - eagerly sought as a 

signal of CCP and central government approval, as well as 

an opportunity for profitable work-that entitle them to 

conduct classified research and development on weapons 

and equipment for the PLA, and such institutions are 

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Arms Control and International Security Papers 

Technology Transfers to the PRC Military and U.S. Countermeasures: 

Responding to Security Threats with New Presidential Proclamation 

critical components of the MCF apparatus. The PRC has 

also established National Defense Science, Technology, 

and Industry MCF Innovation Bases around the country, as 

well as MCF dual-use technology centers, MCF industrial 

parks, and other joint R&D facilities at which civilian firms 

and universities partner with defense sector firms and more 

traditionally defense-oriented universities for 

collaboration. 

In the words of the state news agency Xinhua in 2018, 

the entire Chinese university system is considered to be the 

"front line" of MCF. And, as I testified to a U.S. 

Congressional commission in June 2019, 

"[a]s befits the priority given to the 'front line' in any 

kind of struggle, the MCF system is working along 

multiple lines of effort to advance Chinese capabilities 

through the development of a talent pool of doctoral, 

masters, and undergraduate-level workers in STEM 

fields. The Chinese government certifies universities 

to undertake classified research and development on 

military contracts, as well as certifying them for 

weapons production - a policy known in China as the 

'three certifications.' ... [T]his approach also includes 

implementing a policy under which state-owned 

defense enterprises fund the education of students at 

the undergraduate, masters, and doctoral level - even 

to the point of providing living stipends. These student 

subsidies turn their recipients into something akin to 

employees of China's defense industry, especially since 

this support is given in return for a service commitment 

from the students to the companies that fund their 

education." 

Such practices of systematic "background obfuscation" can 

make it difficult to tell which Chinese researchers are 

"purely" civilians and which ones are being sent abroad, 

including by the PLA itself, to undertake advanced research 

and R&D in support of MCF objectives. 

While many countries, including the United States, use 

civilian talent to advance military programs, MCF is 

fundamentally different and at odds with international 

norms and practices. For example, the United States and 

its allies and partners all strictly observe a set of norms that 

govern permissible uses of certain technologies acquired 

through international trade. Trade in advanced, sensitive, 

and emerging technologies, in particular proliferationsensitive advanced and dual-use technologies, is only 

possible by having confidence that end users will abide by 

the stated end-use and not divert it to unauthorized 

Volume I, Number 9 I June 5, 2020 

purposes, such as military end uses. In implementing MCF, 

however, the PRC system is specifically seeking to 

eliminate the barriers between China's civilian research and 

commercial sectors, and its military and defense industrial 

sectors; if successful, MCF will render such a distinction 

between those two sectors meaningless. 

The U.S. Federal Bureau of Investigation periodically 

publishes information designed to draw attention to the 

counterintelligence and economic espionage dangers 

presented by incautious engagement with PRC students 

and researchers, but it may be useful here to offer some 

illustrations: 

• A student working with an American aerospace 

engineering professor at a U.S. university claimed to 

be affiliated with a PRC civilian institution, but turned 

out to be an expert on anti-satellite technology whose 

China-based address in the university directory 

corresponded to a college for PLA officers. 

• A professor at a U.S. university who contributed to that 

university's classified work for the U.S. Department of 

Defense turned out to be a member of the PRC's 

"Thousand Talents Program" and both an advisor for a 

PRC government research institute and the lead 

scientist on an advanced technology project. This 

professor provided his institute in the PRC with 

research that closely resembled his classified work for 

the U.S. Defense Department. 

• A biomedical researcher who entered the United 

States on a J-1 (student) visa ostensibly to conduct 

cancer-cell research at Beth Israel Deaconess Medical 

Center in Boston was arrested trying to smuggle 21 

vials of research material to the PRC, and subsequently 

charged on multiple counts. 

Such cases, alas, are distressingly common. 

An additional aspect of these challenges at which we 

have been looking with increased concern in recent years is 

the activity of something called the China Scholarship 

Council (CSC), a non-profit organization affiliated with the 

PRC's Ministry of Education that supports international 

academic exchanges with China. We have become 

concerned that its programming sometimes closely tracks 

MCF directives to target sensitive U.S. research and 

development efforts, often with military applications, 

particularly in the United States and other Western 

countries. In January 2020, for instance, the CSC 

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Arms Control and International Security Papers 

Technology Transfers to the PRC Military and U.S. Countermeasures: 

Responding to Security Threats with New Presidential Proclamation 

sponsored a student to study at Boston University. The 

U.S. Department of Justice later charged her with illegally 

acting as an agent of a foreign government after she 

concealed her affiliation with the PLA's National University 

of Defense Technology and pretended to be a civilian. (In 

fact, she was a PLA lieutenant.) CSC recipients must 

submit to embassy and consulate "management" abroad, 

which leaves them vulnerable to coerced participation in 

this and other types of activities - not only commanddirected political agitation, but also potentially activities in 

support of MCF objectives. It is hard to escape the 

conclusion that CSC today sometimes functions as yet 

another instrument of the MCF apparatus. 

All in all, therefore, we clearly have a problem on our 

hands. One way in which we try to meet these threats -

while yet maximizing the benefits that can still flow from 

widespread international economic and technological 

interaction, including with PRC entities - is through visas. 

In addition to things such as law enforcement concerns, it is 

a well-established practice to screen visa applications for 

potential problems related to the proliferation of weapons 

of mass destruction (WMD), missile technology, 

conventional arms, and sensitive dual-use items. (Indeed, 

this is a major responsibility for my bureau at the U.S. 

Department of State, where we already vet more than 

1001000 visa applications for such concerns every year.) 

The new U.S. rules affecting the entry of certain PRC 

nationals represent a modest and measured adjustment to 

U.S. procedures in response to the demonstrable 

challenges created by the "Military-Civil Fusion" strategy. 

Ill. The New Approach 

The new U.S. rules suspend the entry into the United 

States of any PRC nationals seeking F visas or exchange 

visitors seeking J visas to study or conduct research in the 

United States, except for a student seeking to pursue 

undergraduate study, who either receives funding or is 

currently employed by, studies at, or conducts research at 

or on behalf of an entity in the PRC that we understand to 

be engaged in implementing or supporting MCF. In 

addition, the rules suspend entry of any PRC national 

seeking For J visas, except to pursue undergraduate study, 

who has been employed by, studied at, or conducted 

research at or on behalf of an entity in the PRC that we 

understand to be engaged in implementing or supporting 

MCF. 

It is worth emphasizing how focused, moderate and 

nuanced an approach this is, given the magnitude of the 

Volume I, Number 9 I June 5, 2020 

threat and the soaring ambition of the PRC's MCF strategy 

to incorporate essentially the entirety of China's civilian 

science and technology ecosystem for purposes of 

boosting the PLA's military might and supporting the CCP's 

destabilizing global revisionism. We are keenly aware of 

the enormous benefits that accrue to both countries as the 

brightest minds from around the world come to America as 

students and researchers, thereby enriching our superior 

system of higher education and the multiple dynamic and 

innovative sectors of our economy that still represent the 

global "Gold Standard" for excellence. As I have 

emphasized before, 

"[t]hat we are able to attract top minds from all over 

the world speaks to the strength of our values, our 

education system, and our scientific prowess, and our 

universities' programs are all the stronger as a result. 

Many international students make significant 

contributions to science and technology, and would 

probably like to stay in the United States .... " 

(As an example, no one can forget that nearly a fifth of the 

Fortune 500 companies were founded by immigrants.) We 

have no desire to damage these invaluable relationships, 

and our new policy will not do so. 

Yet precisely because the PRC's MCF strategy does 

target U.S. universities, laboratories, companies, and other 

institutions on the cutting edge of the 21st Century's 

technological frontiers, the "business as usual" approach to 

engagement with the PRC that prevailed for decades 

before the U.S. public policy community awakened to 

these problems cannot be maintained. In light of what we 

now understand all too clearly about the PRC's approach to 

these issues, we have little choice but to prevent entry of 

those at highest risk of being exploited or co-opted by 

Beijing in order to come here not for mutual benefit but 

instead to exploit our openness, and to appropriate for the 

CCP whatever it thinks will help Xi Jin ping achieve his 

"Dream" of giving the PRC a military with capabilities 

superior to that of any other country by 2049. 

Accordingly, we are seeking to strike a balance with 

this new policy, for we wish neither to impose some kind of 

technological "embargo" upon the PRC nor to allow it to 

continue plundering our intellectual property and diverting 

this knowledge to the PLA and the PRC security services. 

Much as we recently declared about our new approach to 

national security export controls vis-a-vis Huawei, 

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Arms Control and International Security Papers 

Technology Transfers to the PRC Military and U.S. Countermeasures: 

Responding to Security Threats with New Presidential Proclamation 

"the right answer surely lies between such 

asymptotes, and - as in so many other arenas -we will 

all suffer ifwe cannot navigate a prudent middle way 

between such extremes. In the arena of national 

security export controls, it is just such an Aristotelian 

Mean of a response that we have been trying to 

implement." 

To this end, for instance, we have made clear that 

"[i]t is extremely important to put some national 

security brakes on the Chinese system's massive 

technology transfer bureaucracy. It is also important, 

however, to avoid the unjustified conclusion that all 

Chinese students or technicians seeking to come here 

are threats - or that the solution to the national 

security problem with which the CCP's strategy has 

confronted us is simply to shut down all ongoing 

engagements with the world's second-largest 

economy . ... Even as we police against those who 

would take advantage of our openness to collect 

technology for those who seek to collect knowledge 

with which to do us harm ... we must also remain open 

and welcoming to Chinese talent that wants to work 

within our university and lab system to help push the 

frontiers of the emerging and even disruptive 

technologies that can help fuel mankind's flourishing in 

the years to come." 

The new U.S. visa rules represent just such a middle 

way. What these new rules will do is to help us protect 

against those relatively few "bad apples" who come to the 

United States under false pretenses, taking advantage of 

our openness, and our ethos of collaboratively pursuing 

knowledge, in order to build up the strength of those who 

wish us ill, and who arm and train themselves while 

envisioning Americans as their principal adversary. What 

these rules will not do is prevent legitimate Chinese 

students and researchers -the overwhelming majority of 

whom are most emphatically "good apples" -from coming 

Volume I, Number 9 I June 5, 2020 

here for mutual benefit as our two economies and two 

cultures try to build a better future together. 

Already, out of the more than 1.5 million Chinese 

visitors who came to America in 2019, only a fraction were 

referred for nonproliferation visa screening, and only a tiny 

proportion were denied. Even as the recently announced 

changes give us new tools with which to fight technologytransfer threats, our new rules are not expected to add 

dramatically to the total number of visa denials, and such 

denials will continue to represent only a small proportion of 

the total pool of applications. 

I have no doubt, of course, that the Chinese 

Communist Party's propaganda apparatus will do 

everything it can to depict our moves in the worst possible 

terms. You should expect, for instance, to hear PRC 

diplomats, Party-controlled media outlets, and overseas 

propaganda assets offer a litany of vaguely substantiated 

but alarming imprecations, claiming that these rules 

supposedly represent paranoid and retrograde Cold War 

thinking which will demolish education and research 

collaboration in the United States. CCP propagandists may 

also try to toss empty ad hominem insinuations of racism 

into the mix, for political effect. This is all fictional 

nonsense. Do not believe any of it. 

To be clear: such attacks will be baseless. The venom I 

expect from the PRC over these rules will merely signal 

Beijing's frustration with the degree to which our new 

restrictions really do represent a setback for the CCP's 

ongoing campaign to rob Americans in an effort to build up 

the People's Liberation Army. Even while PRC 

propagandists vent their spleen, therefore, the United 

States will continue to welcome foreign students and 

researchers - including a great many Chinese ones - and 

our society and economy will continue to benefit from 

mutually beneficial, good-faith engagement with the 

brightest minds from around the world. 

And that is quite as it should be. 

* * * 

6 
Arms Control and International Security Papers 

The Arms Control and International Security Papers are produced by the Office of the Under Secretary of State for Arms Control 

and International Security in order to make U.S. State Department policy analysis available in an electronically-accessible 

format compatible with "social distancing" during the COVID-19 crisis.