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Executive Order

#14282 — Foreign-Gift Transparency (April 23, 2025)

Highlights

Full disclosure of foreign gifts / contracts

Key Compliance/Risk Cue

Qui-tam & OFAC exposure if SDN (specially-designated nationals) are linked to gifts/contracts.

Litigation Snapshot

No current litigation, but increased audit & enforcement risk, including potential qui tam FCA claims or APA challenges.

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