Foreign Gifts & Contracts Required Information

Use the following guidelines to provide specific information for each foreign gift and contract received by The George Washington University.

Background and Purpose

Section 117 of the Higher Education Act of 1965, as amended (“HEA”), requires institutions that participate in the Title IV student assistance programs to file a disclosure report with the U.S. Secretary of Education (“Secretary”) containing information about gifts received from any foreign source, contracts with a foreign entity, and any ownership interests in or control over the institution by a foreign entity.  The disclosure report is required if the institution “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” 20 U.S.C. § 1011f (a).  An institution must file the disclosure report by January 31 and July 31, whichever is sooner, after the date of receipt of the gift or date of the contract. The report filed on July 31 covers the period January 1 – June 30 of that year.  The report filed on January 31 covers the period July 1 – December 31 of the prior year.


In order for University to comply with the HEA reporting deadline, gifts and contracts across the university must be aggregated properly to evaluate whether the reporting threshold has been met.  Accordingly, departments, offices, schools or other units receiving gifts of any dollar value from a foreign source must promptly report such gifts to the Office of the Vice President for Development and Alumni Relations (DAR) at 202-994-6415 in accordance with the Gift Acceptance Policy.  All contracts of any dollar value with foreign sources are reported to Financial Reporting in the Office of the University Controller twice a year through the HEA reporting cycle.  In consultation with DAR and other appropriate University schools and divisions, Financial Reporting will prepare and submit all foreign source gift and contract disclosure reports to Secretary of the Department of Education.

For gifts received from or contracts entered into with a foreign source as defined in the Foreign Gifts and Contracts Disclosure Policy, provide the following for each such gift or contract:

  1. Country1
  2. Amount
  3. Legal name of Foreign source
  4. Government, non-government entity, or individual
  5. Contract start date received
  6. Contract end date
  7. Description of conditions or restrictions (if required)
  8. Specific restricted or conditional contract provisions (if required)
    • the employment, assignment, or termination of faculty;
    • the establishment of departments, centers, research or lecture programs, or new faulty positions;
    • the selection or admission of students; or
    • award of grants, loans, scholarships, fellowships, or other forms of financial aid restricted to students of a specified country, religion, sex, ethnic origin, or political opinion.


1The country to which a gift is “attributable” is the country of citizenship if the giver is a natural person, or the country of incorporation if the giver is a legal entity. If the person’s country of citizenship is unknown, use their country of principal residence. If the legal entity’s country of incorporation is unknown, use the country that is its principal place of business.

Last Amended Date: June 1, 2021