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Florida’s New Restrictions on Foreign Donations to Nonprofits (SB 700): What Charities, Donor-Advised Funds, and Fundraisers Must Do Now

The Core Rule (and Who Is Covered)

• Who is covered? SB 700 applies broadly to “any person” involved in planning, conducting, or executing charitable solicitations or charitable sales promotions in Florida. That includes registered nonprofits, professional solicitors and fundraising consultants, commercial co-venturers (cause-marketing), and any out-of-state charity that solicits in Florida (online or offline).
• What is prohibited? Covered parties may not solicit or accept “contributions, funding, support, or services” from a foreign source of concern—no de minimis threshold and no indirect workarounds via intermediaries. If the money or “thing of value” can be traced to a restricted source, it’s out.
• Which countries? Florida tracks the state’s existing “foreign countries of concern” framework: China, Russia, Iran, North Korea, Cuba, Syria, and Venezuela (Maduro regime).
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New Compliance Architecture: Attestations and the “Honest Services Registry”

• Attestation requirement. Charities registering (or renewing) to solicit in Florida must attest compliance with the foreign-donor ban as part of their charitable solicitation filings. Expect the attestation to become a standard element of annual registration.
• Honest Services Registry (optional listing). Florida will stand up a public-facing list for organizations that choose to be listed after certifying compliance—designed to signal “clean fundraising.” While optional, many nonprofits may opt in for donor confidence and peer accountability.
• Enforcement & penalties. SB 700 is housed within Chapter 496 (Solicitation of Funds)—the same framework that authorizes administrative actions, fines, suspensions, and revocations for solicitation violations. The Florida Department of Agriculture and Consumer Services (FDACS) oversees registration and enforcement.
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Practical Impacts for Different Nonprofit Models

1) Traditional charities (human services, education, arts, faith-based)

• Update gift acceptance policies to explicitly bar contributions from covered foreign sources (including in-kind support and services).
• Add donor attestations (self-certifications) to all giving channels—online forms, event pledges, DAF letters, and major-gift agreements.
• Train staff and volunteers to decline or refund prohibited gifts and to escalate edge cases (e.g., U.S. subsidiaries of foreign conglomerates).

2) Donor-advised funds and community foundations

• Embed foreign-source screening in inbound DAF contributions and outbound DAF-to-charity grants that follow Florida-targeted solicitations.
• Require certifications from sponsoring organizations and adopt exception workflows for complex pass-through gifts.

3) Universities, independent schools, and alumni associations

• Combine SB 700 screening with existing foreign gift reporting and export-control policies.
• Pay special attention to sponsored research, endowed chairs, and naming-rights gifts with overseas linkages.

4) Cause-marketing and commercial co-venturers

• Refresh co-venture contracts to (a) bar covered support, (b) require representations and warranties from the brand partner about funding sources, and (c) mandate notice and cure if red flags arise.
• Build supplier screening into campaigns to catch restricted support routed through distributors or affiliates.
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A 10-Step Compliance Checklist (Start Now)

• Map your Florida touchpoints. Inventory every solicitation channel that touches Florida donors: website forms, QR codes, P2P pages, events, telemarketing, mailers, corporate campaigns.
• Adopt a targeted policy. Update the gift acceptance policy to prohibit contributions, support, or services from foreign sources of concern—including indirect flows. Cross-reference definitions to SB 700.
• Add donor questions & attestations. Insert a yes/no question and checkbox attestation to giving forms: “I (we) are not a government, party, entity, or person associated with a foreign country of concern (China, Russia, Iran, North Korea, Cuba, Syria, Venezuela) and no part of this gift originates from such a source.”
• Build an exceptions workflow. For major gifts or complex entities (e.g., U.S. subsidiaries), route to legal/compliance for enhanced due diligence (ownership, control, source of funds).
• Train your frontline. Educate development officers, campaign volunteers, board members, and call centers on the new rules; give them scripts for declines and refunds.
• Update vendor agreements. Require professional fundraisers and agencies to comply with SB 700, maintain records, and indemnify for noncompliance.
• Refresh co-venture agreements. Add representations, audit rights, and termination for foreign-source violations in cause-marketing campaigns.
• Document everything. Keep attestations, refusals, refunds, and red-flag memos with campaign files for three to five years (align with your record-retention schedule).
• Coordinate with finance/tax. Ensure GL coding flags refunded/declined gifts due to SB 700 and that Form 990 disclosures remain accurate.
• Consider the Honest Services Registry. If your donor base values transparency, opt in once FDACS opens enrollment, and publicize your listing.
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FAQs (Answer These for Your Board and Donors)

Board-Level Talking Points

• Mission protection: The law reduces geopolitical and reputational risk around funding sources.
• Donor confidence: Public attestation and the optional registry listing can enhance trust and conversion rates.
• Fundraising continuity: A clear decline/refund protocol avoids emergency calls mid-campaign.
• Cost of noncompliance: Administrative actions can disrupt campaigns and grant cycles—treat screening as front-end hygiene, not back-end cleanup.

Model Language You Can Adapt (Policy + Form)

What to Do This Week

• Add the attestation to every Florida-facing form (web, pledge cards, DAF letters).
• Train your frontline fundraisers and enable decline/refund workflows.
• Update contracts with third-party fundraisers and co-venture partners.
• Draft your FDACS attestation for the next registration cycle and consider the Honest Services Registry listing.

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