The Real Immigration Enforcers, and Northwestern's vital role in the perpetuation of the American Immigration system
By: Jeremiah Nabors-Moore
Edited by: Lana Alnajm and Eleanor Bergstein
Northwestern University has consistently reiterated in its statements that students from more than one hundred countries are “critical to our shared academic success” and that the institution “cannot do [its] best work without attracting the best minds from around the world.”¹ It is clear that on paper, Northwestern not only values its international students, but in many ways relies on them. This becomes even more apparent when you consider the financial benefit that international students bring. Around 70% of international students pay roughly the full cost of tuition, approaching six figures annually, and even have to demonstrate their ability to pay prior to receiving documents.² ³ ¹⁵ These students represent hundreds of millions of dollars in stable tuition revenue for the university.⁴ That is not even considering the myriad other benefits that accompany having international students on campus. And yet, despite the university’s affinity for international students, it seems to have no qualms about potentially harming them the moment it comes under pressure. Many were surprised by this decision and questioned how a university that purports to support its students could agree to these terms. However, when you examine the Northwestern legal position on the management of internationals, their decision makes perfect sense.
After the Trump administration's months-long funding freeze last spring, the university was able to negotiate a deal with the administration to get the money back.⁵ However, this deal came with a cost. In exchange for the return of approximately $790 million in frozen federal funding, the university agreed to a multitude of stipulations relating to international students, including developing training materials to “socialize international students” to campus norms and examining the university’s financial reliance on foreign student admissions.⁵ The agreement also required Northwestern to provide detailed admissions and compliance data and to uphold federal anti-discrimination standards.⁵
Experts have pointed out that many of these stipulations could end up harming international students. In an interview with the executive director and chief executive of NAFSA: Association of International Educators, Fanta Aw, she questioned the possibility that giving students socialization training could be as though the University was assuming that international students were up to something dubious. Additionally, an international student interviewed in the same article stressed how she did not want to be taught how to think.¹⁶ It is clear that the perception of these new trainings could be perceived as discriminatory, steering international students away from applying, and for those forced to do the trainings, to signal them out and cause harm. The request for international student admission data is also concerning, as the White House asked for it in tandem with a request that the university examine its reliance on international students. These requests are clear indicators that the administration is not satisfied with the current number of international students, and could lead to future requests to downsize class size. For a university that presents itself as a supporting entity for its international students, it becomes difficult to justify policies that could do immeasurable harm. This contradiction, however, makes much more sense when you re-examine the university’s role in the federal immigration system. Northwestern is not simply a private entity when admitting and managing its international students, but an extension of the federal immigration process, due to its role in the termination of status for international students, and reliance on the federal government for support in the management of the group.
To show how Northwestern is connected to the immigration system, it is important to examine its relationship with the F-1 visa status that international students are required to obtain, and its role in the possible termination of that status. It is often a misconception that international students on campus have stable legal protection while studying in the United States. It is true that the university might claim that they support international students, yet most international students are admitted into the U.S. on what is called an F-1 visa status, which derives from the Immigration and Nationality Act (§101(a)(15)(F)), which serves as the foundation of America's immigration law.⁶ ⁷ The F-1 visa status is reserved for noncitizens “who seek to enter the United States temporarily and solely for the purpose of pursuing a course of study” at an approved institution.⁷ The keyword is temporary; internationals are only permitted to study in the U.S. so long as they are continuing their studies and following the restrictions that come with the status. These restrictions fall under 8 CFR §214.2(f)⁸ —the regulatory layer for F-1 visa status. Things that F-1 holders are restricted from doing can include freely working in the U.S. labor market (8 C.F.R. §214.2(f)(9)–(10)),⁹ dropping below full time academic enrollment/not making normal academic progress (8 C.F.R. §214.2(f)(6)–(8)),¹⁰ failing to update an address change in ten days (8 C.F.R. §214.2(f)(17), §214.3(g)),¹¹ and other failures to update changes in condition. All of these violations can lead to what is called a termination of visa status under 8 C.F.R. §214.2(f).¹² Universities are required to report violations pursuant to 8 C.F.R. §214.3(g),¹³ and they learn of most status violations through ordinary academic and administrative records—course registration, employment paperwork, or enrollment status—rather than immigration enforcement activity, meaning routine campus data flows function as the operative trigger for federal immigration consequences under 8 C.F.R. §§214.2(f) and 214.3(g),¹² ¹³ essentially turning the university into a quasi immigration enforcer. The State Department, which is the grander manager of America's immigration system, has little discretion in status termination, and if the student has committed a violation that has not been approved, status will immediately be terminated.
Now, the termination of an international student's status and the termination of their visa are two completely different things. A visa and status are legally distinct. A visa, issued and revoked only by the U.S. Department of State, is merely an entry document that allows a person to request admission at the border.¹⁴ Status, by contrast, is the person’s lawful permission to remain inside the United States under a specific category (like F-1 student) and is governed by compliance with INA §101(a)(15)(F) and 8 C.F.R. §214.2(f).⁷ ⁸ When a university reports a violation, the student’s status can be terminated immediately under 8 C.F.R. §214.2(f),¹² making their presence unlawful even if the visa stamp in the passport remains valid. Conversely, a visa can be revoked while the person is still lawfully present inside the country. In short, visa revocation affects the ability to enter; status termination affects the ability to stay. Overall, Northwestern's requirement to report to DSO’s effectively removes them as a neutral party in immigration enforcement and actively positions them as part of the enforcement process, despite Northwestern being a private institution. This is how the system has always been, even before the deal with the Trump administration.
The product of this arrangement between the federal government and the university is not just joint compliance, but an assimilation. Federal immigration law has previously not monitored individual students directly. Instead, under 8 C.F.R. §§ 214.2(f) and 214.3(g),¹² ¹³ it deputizes universities to track enrollment, employment authorization, academic progress, and reporting obligations, and to enter termination decisions into SEVIS when violations occur. The university’s administrative determination becomes the operative legal event that ends lawful presence under 8 C.F.R. §214.2(f).¹² In effect, immigration enforcement authority is partially privatized, embedded within ordinary university bureaucracy. This arrangement places Northwestern in a hybrid role. It remains a private educational institution in form, yet exercises a function that carries sovereign consequence. Unlike traditional government enforcement, however, this delegated system operates without the procedural safeguards typically associated with public adjudication. The power to trigger immigration consequences is exercised through administrative data entry rather than judicial review.
All of this puts Northwestern's decision to capitulate to the Trump administration and agree to these potentially harmful terms regarding the fate of international students on campus into context. Northwestern, as a key part of the immigration system concerning international students, is not agreeing with a separate entity but rather with its own boss in the overall immigration hierarchy. Advocates and students were upset at this decision and surprised that the university would agree to such potentially damaging terms. However, with this context, the university's decision to capitulate in this manner was inevitable. It is difficult to expect a cog in a machine to go into conflict with its operator. Northwestern is structurally embedded in the immigration enforcement system, bound by federal regulation and dependent on federal funding. That position makes true neutrality impossible. It cannot fully stand as a shield for its international students while simultaneously serving as a reporting arm of the federal government. Until that structural conflict is acknowledged and addressed, international students will continue to bear the legal risks of a system from which the university materially benefits.
Notes:
Northwestern University, Leadership Notes on International Students, https://www.northwestern.edu/leadership-notes/2025/resources-related-to-federal-action-on-immigration-and-travel.html
Northwestern University, 2025–26 Tuition and Fees Announcement, https://news.northwestern.edu/stories/2025/05/northwestern-sets-tuition-fees-and-financial-aid-for-2025-2026-academic-year/
Northwestern Office of International Student and Scholar Services, Financial Documentation Requirements, https://www.northwestern.edu/international/international-students/steps-newly-admitted/financial-documentation-requirements.html
Institute of International Education, Open Doors Economic Impact Report, https://opendoorsdata.org/annual-release/economic-impact/
Northwestern University, Presidential Statement on Federal Funding Agreement, https://www.northwestern.edu/president/news/federal-agreement/
U.S. Immigration and Customs Enforcement, Student and Exchange Visitor Program Overview, https://www.ice.gov/sevis
Immigration and Nationality Act §101(a)(15)(F), 8 U.S.C. §1101(a)(15)(F), https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title8-section1101
8 C.F.R. §214.2(f), https://www.ecfr.gov/current/title-8/section-214.2
8 C.F.R. §214.2(f)(9)–(10), https://www.ecfr.gov/current/title-8/section-214.2
8 C.F.R. §214.2(f)(6)–(8), https://www.ecfr.gov/current/title-8/section-214.2
8 C.F.R. §214.2(f)(17); 8 C.F.R. §214.3(g), https://www.ecfr.gov/current/title-8/section-214.2
8 C.F.R. §214.2(f), https://www.ecfr.gov/current/title-8/section-214.2
8 C.F.R. §214.3(g), https://www.ecfr.gov/current/title-8/section-214.3
U.S. Department of State, Visa Information, https://travel.state.gov/content/travel/en/us-visas.html
Kang, “NU Should Practice Need-Blind Admissions for All,” The Daily Northwestern, January 30, 2023, https://dailynorthwestern.com/2023/01/30/lateststories/kang-nu-should-practice-need-blind-admissions-for-all/?utm_source=chatgpt.com
“In Northwestern’s Trump Agreement, International Students Singled Out for Open Debate Training,” The Chronicle of Higher Education, https://www.chronicle.com/article/in-northwesterns-trump-agreement-international-students-singled-out-for-open-debate-training?utm_source=chatgpt.com
Bibliography:
Institute of International Education. Open Doors Report on Economic Impact of International Students. Accessed March 24, 2026. https://opendoorsdata.org/annual-release/economic-impact/.
Kang. “NU Should Practice Need-Blind Admissions for All.” The Daily Northwestern, January 30, 2023. https://dailynorthwestern.com/2023/01/30/lateststories/kang-nu-should-practice-need-blind-admissions-for-all/?utm_source=chatgpt.com.
Northwestern University. “Leadership Notes: Resources Related to Federal Action on Immigration and Travel.” Accessed March 24, 2026. https://www.northwestern.edu/leadership-notes/2025/resources-related-to-federal-action-on-immigration-and-travel.html.
Northwestern University. “Northwestern Sets Tuition, Fees and Financial Aid for 2025–2026 Academic Year.” Northwestern News, May 2025. https://news.northwestern.edu/stories/2025/05/northwestern-sets-tuition-fees-and-financial-aid-for-2025-2026-academic-year/.
Northwestern University. “Presidential Statement on Federal Funding Agreement.” Accessed March 24, 2026. https://www.northwestern.edu/president/news/federal-agreement/.
Northwestern University Office of International Student and Scholar Services. “Financial Documentation Requirements.” Accessed March 24, 2026. https://www.northwestern.edu/international/international-students/steps-newly-admitted/financial-documentation-requirements.html.
United States. Immigration and Nationality Act, 8 U.S.C. § 1101(a)(15)(F). Accessed March 24, 2026. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title8-section1101.
United States. Code of Federal Regulations. Title 8, § 214.2(f). Accessed March 24, 2026. https://www.ecfr.gov/current/title-8/section-214.2.
United States. Code of Federal Regulations. Title 8, § 214.3(g). Accessed March 24, 2026. https://www.ecfr.gov/current/title-8/section-214.3.
U.S. Department of State. “U.S. Visas.” Accessed March 24, 2026. https://travel.state.gov/content/travel/en/us-visas.html.
U.S. Immigration and Customs Enforcement. “Student and Exchange Visitor Program (SEVP).” Accessed March 24, 2026. https://www.ice.gov/sevis.
The Chronicle of Higher Education. “In Northwestern’s Trump Agreement, International Students Singled Out for Open Debate Training.” Accessed March 24, 2026. https://www.chronicle.com/article/in-northwesterns-trump-agreement-international-students-singled-out-for-open-debate-training?utm_source=chatgpt.com.