Relating to establishing the hostile foreign adversaries unit at the Department of Public Safety and training, prohibitions, and reporting requirements designed to combat foreign influence and foreign adversary operations; creating a criminal offense.

Contracts

• Government MSAs: Expect state agencies and local governments to amend Master Service Agreements immediately. They will require indemnification clauses where you certify you are not "acting on behalf of a foreign adversary."
• Lobbying Agreements: You must amend contracts with external lobbyists to include a strict "Duty to Report" clause for any foreign contacts, as their failure to report imputes liability to your organization.
• Employment Agreements: Update executive and sales contracts to explicitly prohibit offering gifts or travel to public officials if the funding source originates from a designated adversary nation.

Hiring/Training

• Cybersecurity Certification: By May 1, 2026, cybersecurity training programs must include modules on "United Front Work Department" tactics. Verify your training vendors are preparing this content.
• Internal Training: Staff interacting with government officials must be trained on the specific definition of "foreign adversary" (currently China, Russia, Iran, North Korea) and the strict prohibition on gifts/travel.

Reporting & Record-Keeping

• The "Look-Back" Log: You must implement a CRM tag or manual log to track *all* interactions with foreign entities starting March 1, 2025.
• Catch-Up Filing: A consolidated report for all interactions between March 1, 2025, and September 1, 2025, must be filed with the TEC by October 1, 2025.
• Rolling Disclosures: Ongoing interactions must be reported within 30 days of occurrence.

Fees & Costs

• Legal Defense Gap: Review your Directors & Officers (D&O) insurance. Most policies exclude criminal defense costs. Since violations are State Jail Felonies, your current policy likely leaves your officers exposed.
• Indirect Costs: Budget for increased legal counsel review of international travel and vendor vetting.