Navigating New Restrictions Under Florida’s Charitable Solicitation Act

Florida’s recent amendments to its Charitable Solicitation Act mark a significant shift in nonprofit regulation, according to an article by Heidi K. Abegg of Whiteford, Taylor & Preston LLP. 

Effective July 1, 2025, the law prohibits nonprofits registered to solicit in Florida—including §501(c)(3) and §501(c)(4) organizations—from soliciting or accepting contributions or anything of value from a “foreign source of concern.” This prohibition applies not only in Florida but to all solicitations and fundraising activities conducted by covered entities, their partners, and affiliates, regardless of location.

The law defines foreign sources of concern broadly, including governments, political parties, organizations, and individuals linked to countries such as China, Russia, Iran, North Korea, Cuba, Venezuela (under Nicolás Maduro), and Syria. Importantly, the statute contains no thresholds or scienter requirements, meaning even a minimal contribution or volunteer service could trigger a violation. 

The lack of clarity around what qualifies as “something of value” further complicates compliance, particularly for nonprofits engaging with donor-advised funds, U.S. companies with partial foreign ownership, or international partnerships.

Florida’s Charitable Solicitation Act aligns with a broader national trend. Abegg highlights that several states, including Nebraska, Arkansas, Texas, Louisiana, and Utah, have enacted or are implementing “Mini FARA” laws or related disclosure rules targeting foreign influence. These measures vary in scope but collectively represent an expanding regulatory environment in which nonprofits must carefully vet donors, sponsors, and partners.

For compliance teams working with nonprofits, it is essential to audit funding sources, evaluate board and partner affiliations, and strengthen due diligence processes before these state-level requirements take effect. The evolving landscape requires proactive compliance strategies to manage the heightened risks associated with scrutiny of foreign influence.