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Reporting Foreign Gifts and Contracts: 

Over 30 years ago, Congress enacted Section 117 of the Higher Education Act of 1965 (HEA) in light of concerns about the growing financial relationship between U.S. universities and foreign sources. Congress balanced academic freedom and national security by mandating financial transparency through required reporting of contracts with and gifts from a foreign source that, alone or combined, are valued at $250,000 or more in a calendar year.

Stony Brook University is committed to complying with reporting requirements of contracts with and gifts from foreign sources.  In support of this commitment, University units receiving Gifts from or entering into Contracts with Foreign Sources must report such Gifts and Contracts semiannually.

Title IV of the HEA requires all institutions that process U.S. federal student aid to disclose semiannually to the U.S. Department of Education specific financial transactions pursuant to Section 117. The requirement states, with regard to the disclosure report:

“Whenever any institution is owned or controlled by a foreign source or receives a gift from or enters into a contract with a foreign source, the value of which is $250,000 or more, considered alone or in combination with all other gifts from or contracts with that foreign source within a calendar year, the institution shall file a disclosure report with the Secretary on January 31 or July 31, whichever is sooner.”


  • Contract - Any agreement for the acquisition by purchase, sale, lease, or barter of property or services by the Foreign Source, for the direct benefit or use of either of the parties.
  • Foreign Source - Any one 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 thereof; and 4) an agent, including a subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source.
  • Gifts - The voluntary transfer of money or property by a Foreign Source made without consideration.