Effective July 1, 2025, a recently enacted Florida law, Senate Bill 700, will broadly prohibit those involved with charitable solicitations or sales promotions from receiving or soliciting funds from individuals and entities associated with certain foreign countries.
The law establishes an “Honest Services Registry”, which will list only those nonprofits that certify they are not influenced by—and do not accept support from—any “foreign source of concern.”
Charitable organizations, as well as fundraising professionals and cause marketing programs operating in Florida, should consider updating their contribution forms to include donor attestations to screen for ties to restricted foreign sources.
Nonprofits, professional solicitors, consultants, and commercial co-venturers should also carefully assess their interactions with foreign persons or organizations to determine whether the law’s restrictions or disclosure obligations apply to them.
Scope of the Prohibition
The law prohibits soliciting or receiving donations—or anything of value—from entities or individuals identified as “foreign sources of concern” originating from designated “foreign countries of concern.” This applies to the planning, execution, or promotion of any charitable fundraising or cause marketing effort within Florida.
The restrictions apply to:
- Public charities
- Private foundations
- Social welfare organizations classified under 501(c)(3) and 501(c)(4) of the Internal Revenue Code
- Professional fundraisers and consultants
- Commercial co-venturers
Multinational corporations and nonprofits with ties to foreign interests may also be affected if they attempt to raise funds from Florida residents for charitable projects abroad.
Definition of “Foreign Sources of Concern”
The countries currently designated as foreign countries of concern include:
- The People’s Republic of China
- The Russian Federation
- The Islamic Republic of Iran
- The Democratic People’s Republic of Korea
- The Republic of Cuba
- The Venezuelan regime under Nicolás Maduro
- The Syrian Arab Republic
Entities or individuals considered “foreign sources of concern” include:
- Governments or officials representing the above countries
- Political parties or members/subdivisions of those parties within the listed countries
- Organizations, corporations, associations, or partnerships formed under the laws of, or headquartered in, any of the countries of concern, including their subsidiaries
- Individuals domiciled in these countries who are not U.S. citizens or lawful permanent residents
- Agents acting on behalf of any of the above
- Any person or entity in which a foreign principal from the above categories holds a controlling interest
The law defines “controlling interest” broadly, referring to the authority—directly or indirectly—to direct an entity’s operations or policies through ownership, contracts, or other means. Holding 25% or more of voting rights or profit share constitutes a presumption of control.
Enforcement and Penalties
Failure to comply may result in civil penalties and could lead to disqualification from conducting charitable fundraising or promotional activities in or from the state of Florida.
The Honest Services Registry
Senate Bill 700 also directs the Florida Department of Agriculture and Consumer Services to create a publicly accessible “Honest Services Registry.”
Nonprofits seeking inclusion in this registry must affirmatively certify that they neither solicit nor accept contributions from foreign sources of concern. Although participation is voluntary, inclusion may serve as an informal indicator of trustworthiness for donors, who may interpret it as a state-vetted list of compliant charities.
The Department is authorized to issue rules governing the operation and implementation of the registry.
Election-Related Compliance
To further insulate the political process from foreign influence, the law imposes new restrictions on nonprofits involved in state and local election-related activities.
Specifically, such nonprofits may not register to solicit charitable contributions—or amend or renew existing registrations—unless they are also registered with the Florida Department of State.
To comply, these organizations must file a signed attestation by an authorized officer confirming:
- Either that they are registered with the Department of State for election-related activities,
- Or that they do not engage in such activities.
Violations may trigger investigation and referral to the Florida Elections Commission, particularly in cases involving social welfare or advocacy groups suspected of political involvement without proper registration.
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