Florida SB 700: New Foreign Funding Restrictions and How Not-For-Profits Can Comply

Effective July 1, 2025, Florida’s Senate Bill 700 (SB 700) introduced sweeping restrictions on who can fundraise and donate to not-for-profits in the state. Outlined below is what this new law does, whom it impacts, the penalties for noncompliance, and the steps not-for-profit leaders should take now to ensure compliance.

What SB 700 Does: Foreign-Source Funding Ban, Required Attestation, and Optional Registry

SB 700 broadly prohibits any person or organization involved in charitable fundraising or promotions from soliciting or accepting contributions that have a direct or indirect link to certain foreign countries of concern.

Foreign Countries of Concern: The law targets seven nations — China, Russia, Iran, North Korea, Cuba, Syria, and Venezuela. It bans donations originating from sources from those countries.

What is a Foreign Source?

• The government, any government official, political party, or member of a political party from a designated country.
• Any organization established under the laws of, or primarily operating in, a designated country including its branches, subsidiaries, representatives, or affiliated entities.
• Individuals residing in a designated country who are not U.S. citizens or lawful permanent residents.
• Any individual or entity in which one of the above parties holds at least a 25% ownership interest or voting control.
• Any representative or intermediary acting on behalf of any of the aforementioned sources.

New Attestation Requirement: SB 700 also adds a certification step to Florida’s charitable solicitation registration process. Organizations must now attest under oath that they will not solicit or accept donations from any foreign source of concern. This sworn statement, signed by an officer, becomes part of the public record and carries legal penalties if it is falsified.

Honest Services Registry: The law further establishes an Honest Services Registry — a public list of not-for-profits that voluntarily certify they accept no support from foreign sources of concern. Participation is optional, but being listed could serve as a state-sanctioned mark of credibility for donors.

Who Is Impacted by the New Law?

Virtually all organizations that solicit charitable donations in Florida, including 501(c)(3) public charities, private foundations, 501(c)(4) social welfare groups, and other types of nonprofits or partners of nonprofits that fundraise from the public. Certain exemptions do apply but they are limited.

Penalties for Noncompliance

Not-for-profits that fail to comply with SB 700 face significant consequences, including cease-and-desist orders halting a charity’s fundraising, monetary fines, suspension of solicitation rights, and even criminal charges for willful violations. However, SB 700 provides a one-time safe harbor for an inadvertent first violation. If a charity unknowingly accepts a prohibited donation but had obtained a false “no foreign ties” certification from the donor, and it refunds the gift within 30 days of notice and reports the issue with a corrective plan, regulators will not penalize that initial mistake.

How Not-For-Profits Can Comply with SB 700

Florida’s not-for-profit leaders should take proactive steps now to ensure compliance with SB 700’s foreign donation rules. Key actions include:

• Review Funding Sources: Identify your current donors and funding sources and evaluate any ties to the seven countries of concern. Be prepared to exclude or more closely vet donations associated with those foreign interests.
• Update Donation Forms: Add a clear question or certification to your donation forms asking donors to confirm they are not a foreign source of concern. Keep these donor attestations on file as part of your records.
• Train Your Team and Update Policies: Educate your fundraising staff and volunteers on the new rules and update your gift acceptance policies accordingly. Everyone involved in fundraising should know how to spot prohibited foreign donors and the proper process for declining or refunding such gifts.
• Board Oversight and Attestations: Have your board formally approve the required state attestation that your organization will not accept foreign-source contributions.
• Consider the Honest Services Registry: Weigh the option of joining Florida’s voluntary registry of "foreign-free" charities. By certifying that your not-for-profit accepts no support from foreign sources of concern, you can earn a public listing that may reassure donors.

Other Considerations for Not-For-Profit Leaders

Florida is one of the first states to impose a foreign donor ban on charities, however, members of congress have discussed this potentially rising to the federal level.

Public transparency matters. Donors and the public can see which organizations appear on the Honest Services Registry, so being on (or off) that list could affect a not-for-profit’s reputation with Florida supporters.

How Citrin Cooperman Can Help

Citrin Cooperman’s Not-For-Profit Industry Practice is well-equipped to help your organization navigate complex policy changes. For more information, please contact Stephen Emery.