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Recorded on March 6, 2026, at the Ronald Reagan Building and International Trade Center in Washington, D.C. General Session: Foreign Gifts and Contracts Reporting: What It Requires and Why It Matters This session covers the background of Section 117, current state of the law, potential impact of noncompliance on institutions, what constitutes a foreign source, how to determine transaction amounts, restricted gifts or contracts, covered institutions and entities, and utilizing the new reporting portal. 0:00 Introduction 1:10 Background and History of Section 117 18:01 What Constitutes a Foreign Source 26:54 How to Determine Transaction Amounts 31:17 Contract Reporting 37:40 Covered Institutions and Entities 41:31 Reporting Portal and System 46:32 Subject Matter Expert (SME) Question Panel About the presenters: Paul Moore - Deputy General Counsel and Chief Investigative Counsel Paul R. Moore is the U.S. Department of Education’s Deputy General Counsel and Chief Investigative Counsel. He is leading the Trump administration’s enforcement efforts involving the statutorily required disclosure of foreign funding by universities. Paul also served as Chief Investigative Counsel in the first Trump administration and co-authored the Department’s Oct. 2020 official report on university compliance with foreign funding disclosure requirements (“Institutional Compliance with Section 117 of the Higher Education Act of 1965”), which revealed that many of America’s most prominent universities had failed to disclose billions of dollars in previously undisclosed foreign funding. Paul also served for 12 years at the U.S. Department of Justice, including as an Assistant U.S. Attorney, Senior Counsel in the Office of Legal Policy, and as Counsel to the Assistant U.S. Attorney General for the Civil Rights Division. Lisa Bureau - Chief, Clery Branch Lisa is the Director of the Clery Group in the Institutional Enforcement Division of Federal Student Aid (FSA). The Clery Group’s mission has included responsibility for overseeing and ensuring compliance regarding disclosures of gifts from and contracts with foreign sources by institutions of higher education under Section 117 of the Higher Education Act of 1965, as amended. Lisa previously held the position of Director of Investigations of the Partner Enforcement and Consumer Protection Directorate at FSA. Before joining FSA, Lisa had a long career in the private practice of law, representing institutions of higher education in maintaining their operations in compliance with applicable laws, including providing representation regarding compliance with federal requirements governing participation in the Title IV programs. More about the FSA Training Conference for Financial Aid Professionals (FSATC): https://fsapartners.ed.gov/training/f...