Foreign Gifts and Contracts Guidance
Reporting Requirements
UF is required by both state and federal law to report gifts received from or contracts entered into with foreign sources. This page offers detailed information about these legal requirements.
| Requirements |
Higher Education Act |
Florida Statutes |
|---|---|---|
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Type of Transaction Reported |
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Value Threshold |
$250,000 or more from the same foreign source in a calendar year. To determine whether this threshold is met, UF must aggregate all gifts from and contracts with a foreign source across the UF enterprise. Example: The threshold is met when a foreign source gives a $200,000 gift to the College of Education, a $5,000 gift to the College of Law, and executes a contract with the College of Medicine that is estimated to bring $45,500 in revenue to UF. |
For most foreign sources: $50,000 or more from the same foreign source in a fiscal year. For foreign sources that are foreign countries of concern: $50,000 or more to or from the same foreign source in a fiscal year. To determine whether this threshold is met, UF must aggregate all gifts from and contracts with a foreign source across the UF enterprise. Example: The threshold is met when a foreign source gives a $20,000 gift to the College of Education, a $5,000 gift to the College of Law, and executes a contract with the College of Medicine that is estimated to bring $25,500 in revenue to UF. |
|
Reporting Deadlines |
Semiannually by January 31st and July 31st each year |
Semiannually by January 31st and July 31st each year |
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Additional Requirements |
None |
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Definitions
Division of Sponsored Programs; University of Florida Foundation; UF Innovate; Bursar; Banking and Merchant Services; Disbursements; Procurement.
Any agreement for the acquisition by purchase, lease, or barter of property or services by the foreign source, for the direct benefit or use of either of the parties, and any purchase, lease, or barter of property or services from a foreign country of concern.
People’s Republic of China; Russia; Iran; North Korea; Cuba; Venezuela; Syria
Any of the following: (1) a foreign government, including an agency of a foreign government; (2) a legal entity, governmental or otherwise, created solely under the laws of a foreign state or states; (3) an individual who is not a citizen or a national of the United States or a trust territory or protectorate of the United States; and (4) an agent, including a subsidiary or an affiliate of a foreign legal entity, acting on behalf of a foreign source.
Any gift of money or property including a grant, endowment, award, or donation of money or property of any kind. Gift also includes a conditional or an unconditional pledge of a gift or contract.
A promise, an agreement, or an expressed intention to give a gift or contract.
Examples of Items to Report
Gifts from a foreign source |
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Contracts with a foreign source |
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Responsibilities
All units/departments/offices within the Impacted Entities identified below must semiannually report foreign gifts and contracts to UF Compliance and Ethics (UFCE) in accordance with the guidance and procedures provided in this document.
A. Impacted Entities
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B. Responsible Areas and Data to Report
| Core Reporting Offices | Data to Report |
|---|---|
| Division of Sponsored Programs (DSP) | Sponsored agreements (e.g., grants, contracts, MOUs, etc.) with foreign sources |
| University of Florida Foundation (UFF) |
Gifts, donations, and pledges from foreign sources to the following entities:
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| UF Innovate |
Material Transfer Agreements with foreign sources where compensation is provided
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| Bursar’s Office | Tuition and fees paid by a foreign entity or a foreign student |
| Banking & Merchant Services | Wire transfers from foreign sources |
| Disbursements | As included in myUFMarketplace, any purchase, lease, or barter of property or services from a foreign country of concern |
| Procurement | P-card purchases from countries of concern |
| Other/Non-Core Reporting Offices | Data to Report |
|
All Impacted Areas receiving foreign funds directly without processing the transaction through any of the core reporting offices and/or purchases that did not go through myUFMarketplace |
Any transactions (gifts, contracts, and purchases) from the same foreign source including its subsidiaries and affiliates |
| UF Compliance and Ethics (UFCE) | Any transactions (gifts, contracts, and purchases) from the same foreign source including its subsidiaries and affiliates that alone or in aggregate, across all areas impacted, meet the applicable reporting threshold |
C. Criteria for Reporting
For money flowing in
You received gifts/contracts of any amount from a foreign source, and
The gift/contract was not processed through one of the core reporting offices.
For money flowing out
You purchased goods or services from a foreign country of concern, and
You did not make the purchase through myUFMarketplace.
D. Responsibilities
- Track all gifts or contracts received from any foreign source
- Track goods and services purchased from foreign countries of concern
- Identify subsidiaries and affiliates of foreign sources
- Report all transactions to UFCE by the applicable deadline using the required spreadsheet
- Provide to UFCE with the required supporting documentation for any transactions from the same foreign source when such transactions alone, or when aggregated, meet or exceed $40,000. All supporting documentation must be included in a single PDF no larger than 15 MB.
- Additional information regarding supporting documentation for the FGC report may be found in the FGC User’s Guide.
- Redact agreements where required by law (redacted agreements must be submitted with an abstract)
- If, after the collection period deadline, you identify a foreign gift/contract meeting the threshold of $50,000 that should have been included in a prior report, inform UFCE immediately
References:
Forms:
- Student Sponsorship Summary Form (1 page)
- Student Sponsorship Summary Form (more than 1 page)
- Redacted Agreement Abstract
- No Agreement Memo