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Signed Into Law
Signed June 20, 2025Effective 2025-09-01
SB2514

Regular Session

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.

Government Affairs & Regulatory Compliance Analysis

SB2514: Government Affairs Overview

SB2514 criminalizes unreported interactions with "foreign adversaries" for public officials, effectively forcing private sector vendors and lobbyists to certify their foreign ties to avoid implicating government clients in a State Jail Felony. The law imposes a retroactive reporting requirement starting March 1, 2025, creating immediate liability risks for any business interacting with Texas state or local agencies that has ties to China, Russia, Iran, or North Korea.

Sen. Bryan Hughes·Senate Bill·Regular Session

Critical
Medium Cost
Effective:2025-09-01

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SB2514
Critical
Relating to establishing the hostile foreign adversaries unit at the Department of Public Safety and training, prohibitions, and reporting requirement...
Critical Compliance Urgency
Requires immediate attention
Cost Impact
Medium
Effective
2025-09-01
Enforcing Agencies
Department of Public SafetyLocal Prosecuting AttorneysOAGTexas Ethics Commission
Primary Author: Sen. Bryan Hughes
89th Texas Legislature
jdkey.com
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Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: September 1, 2025
  • Compliance Deadline: March 1, 2025 (Operational "Go-Live"). While the law is effective in September, Section 4 mandates reporting of all interactions occurring on or after March 1, 2025. You must begin tracking interactions on this date.
  • Agency Rulemaking:
  • Texas Ethics Commission (TEC): Must prescribe reporting forms immediately upon the effective date. *Gray Zone:* You must track data from March to September 2025 without a finalized form; maintain raw data logs to populate the form later.
  • Department of Information Resources (DIR): Must adopt rules for cybersecurity training certifications by December 1, 2025.

Immediate Action Plan

  • Immediately audit your supply chain and investor list for ties to China, Russia, Iran, and North Korea.
  • By February 28, 2025, establish a "Foreign Contact Log" protocol to capture data for the retroactive reporting period starting March 1.
  • Issue a directive to all government affairs staff and external lobbyists: "Stop all gifts, travel, and lodging offers to Texas officials if we have any foreign adversary capital backing."
  • Preserve all executive calendars and emails starting March 1, 2025, to ensure the October 1 "catch-up" report is accurate.

Operational Changes Required

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.

Strategic Ambiguities & Considerations

  • "Acting on Behalf Of": The statute fails to define the materiality threshold for when a private business person is considered an agent of a foreign adversary. Until DPS issues guidance, assume any individual with formal ties (e.g., CCP party committee membership) to a foreign government is a reportable contact.
  • "Interaction" Definition: The law requires reporting "each interaction," without a minimum threshold. It is unclear if social media engagement or brief conference greetings count. *Conservative Approach:* Log every substantive communication.
  • Governor's Designation Power: The Governor may unilaterally designate additional foreign adversaries. The list of prohibited countries is fluid; you must monitor Executive Orders continuously.

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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.

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Legislative Timeline

This bill's path through the Texas Legislature

Filed
Mar 13, 2025
Passed Senate
May 5, 2025
Passed House
May 23, 2025
Signed
Jun 20, 2025
Effective
Sep 1, 2025
TopicsCrimesCrimes--miscellaneousGovernorIntergovernmental RelationsLaw EnforcementState EmployeesInternational RelationsStaff Development & TrainingTerrorism & Internal SecurityEthics Commission, TexasPublic Safety, Department ofState Agencies, Boards & CommissionsInformation Resources, Department ofPublic Safety Commission
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Senate Authors

Sen. Bryan HughesRepublican · Primary Author
Coauthors (2)

House Sponsor

Rep. Cole HefnerRepublican · Primary Sponsor

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

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Quick Reference

Frequently Asked Questions

Common questions about SB2514

Q

What does Texas SB2514 do?

SB2514 criminalizes unreported interactions with "foreign adversaries" for public officials, effectively forcing private sector vendors and lobbyists to certify their foreign ties to avoid implicating government clients in a State Jail Felony. The law imposes a retroactive reporting requirement starting March 1, 2025, creating immediate liability risks for any business interacting with Texas state or local agencies that has ties to China, Russia, Iran, or North Korea.

Q

Who authored SB2514?

SB2514 was authored by Texas Senator Bryan Hughes during the Regular Session.

Q

When was SB2514 signed into law?

SB2514 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce SB2514?

SB2514 is enforced by Department of Public Safety (Hostile Foreign Adversaries Unit), Local Prosecuting Attorneys, Office of the Attorney General (OAG) and Texas Ethics Commission.

Q

How significant are the changes in SB2514?

The regulatory priority for SB2514 is rated as "critical". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB2514?

The cost impact of SB2514 is estimated as "medium". This may vary based on industry and implementation requirements.

Q

What topics does SB2514 address?

SB2514 addresses topics including crimes, crimes--miscellaneous, governor, intergovernmental relations and law enforcement.

Q

What are the key dates for SB2514?

Key dates for SB2514: Effective date is 2025-09-01. Rulemaking: Adopt rules implementing new cybersecurity training certification requirements regarding foreign adversaries. (2025-12-01); Establish form and manner for reporting interactions with foreign adversaries. (Immediate upon effective date). Consult with legal counsel regarding applicability.

Q

What are the penalties under SB2514?

SB2514 establishes the following penalties: criminal penalty of State Jail Felony (punishable by 180 days to 2 years in state jail and optional fine up to $10,000) for Knowingly violating prohibitions on gifts/travel or failing to report interactions with foreign adversaries.. Consult with legal counsel for specific applicability to your situation.

Need Strategic Guidance on This Legislation?

JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.

Legislative data provided by LegiScanLast updated: January 11, 2026