Under 8 CFR § 214.3(a)(3) and § 214.4(a)(2)(ii), schools are required to maintain accurate records and comply with all SEVP-related responsibilities, which include ensuring that F-1 students are not engaged in activities that violate status or federal law. If DHS believes that international students were involved in threatening, discriminatory, or unlawful activity and the school either failed to document, disclose, or respond appropriately, that’s a direct compliance issue.
Harvard’s own ASAIB report admits that antisemitic conduct occurred-including exclusion of Jewish students, verbal harassment, and bias in classroom settings. If any of that involved foreign students-and Harvard didn’t report it or take disciplinary action-DHS can reasonably infer noncompliance with 214.3(g)(1) (required records) and failure to enforce visa conditions.
In fact, the ASAIB report might be evidence that Harvard knew about the issues and didn’t fully cooperate, justifying DHS’s conclusion that the university wasn’t acting in good faith.
