PDF of the letter available here.

The Honorable Bryan Steil
The Honorable Joseph D. Morelle

RE:  Support for Robust Privacy Protections for Nonprofits and their Supporters and Caution About Harmful Policy Impacts of Foreign Donor Reporting Schemes

Chairman Steil, Ranking Member Morelle, and Members of the House Committee on House Administration:

On behalf of People United for Privacy (PUFP),[1] I submit the following comments for the hearing record concerning the May 16, 2024 hearing in the U.S. House Committee on House Administration to discuss “American Confidence in Elections: Preventing Noncitizen Voting and Other Foreign Interference.” To the extent Members intend to focus this hearing on allegations of foreigners donating to American nonprofits that then engage in political and issue activity, some important reminders and policy considerations are essential to an informed discussion of this topic.

Fears of foreign involvement in American elections are not new, especially in recent political history. Members of both political parties have seized on anxiety about foreign influence in elections as a pretense for pursuing broader and unrelated political goals. President Obama famously protested in his 2010 State of the Union Address that the Supreme Court’s Citizens United decision would “open the floodgates” for unfettered foreign interference in American elections,[2] prompting Justice Alito to mouth the words “not true” in response to the sensational and misleading claim. More recently, Democrats in Congress have sought to justify privacy intrusions in the so-called “For the People Act”[3] and the “DISCLOSE Act”[4] by pointing to alleged Russian interference in the 2016 election in support of former President Trump.

Nonprofits are the backbone of civil society in America and play an essential role in our democracy. Increased regulation of the nonprofit sector risks a panoply of unintended consequences that will dampen civic engagement and threaten Americans’ First Amendment rights. Legislative or regulatory action aimed at exposing the names and addresses of nonprofit members and supporters poses a particular threat to nonprofits’ willingness to engage on issues core to their mission and risks violating free speech and privacy protections guaranteed by the U.S. Constitution. Our pervasive cancel culture coupled with attacks on nonprofit donor privacy represent one of the most serious threats to free speech and democracy today.

While other issues may be addressed during this hearing, our comments are focused on PUFP’s support for codifying nonprofit donor privacy protections through the “Speech Privacy Act of 2023,”[5] included in the “American Confidence in Elections (ACE) Act”[6] and two measures intended to address concerns about alleged foreign electoral interference.[7] PUFP is concerned that haphazard proposals aimed at tackling such fears will violate hard-earned privacy rights supported by the Speech Privacy Act while simultaneously chilling speech, making compliance difficult or impossible, and incentivizing weaponized and selective enforcement.

I. The Speech Privacy Act of 2023 protects the privacy of Americans who wish to join and support the nonprofit causes of their choice free from harassment and intimidation.

Individuals may legitimately fear any number of damaging consequences from disclosure, including harassment, adverse governmental action, and reprisals by an employer, neighbor, or community member. Or they may simply prefer not to have their affiliations disclosed publicly – or subjected to the possibility of disclosure – for a variety of reasons rooted in religious practice, modesty, or a desire to avoid unwanted solicitations. For nonprofits, privacy is especially important for organizations that challenge the practices and policies of the very government officials that seek the identities of their members and supporters. The Speech Privacy Act of 2023 responds to and resolves these concerns.

Since 2018, 19 states have acted to uphold the U.S. Supreme Court’s Americans for Prosperity Foundation v. Bonta decision, which reaffirmed legal protections for nonprofit donor privacy,[8] by passing new protections against the unlawful collection and disclosure of Americans’ personal information when giving to nonprofits.[9] The Speech Privacy Act of 2023 represents Congress’ intent to prohibit federal agencies from arbitrarily collecting or releasing Americans’ nonprofit membership or donation records. Agencies that are required by law to collect this information, like the Federal Election Commission, are exempted, and penalties for government officials that illegally expose this sensitive information are specified.

Safeguarding Americans’ giving history provides an important defense against the rising trends of doxing and cancel culture, wherein malicious actors weaponize public records and target Americans for harassment based on their beliefs and associations. These actions undermine free speech and jeopardize the ability and willingness of citizens to support the causes of their choice. In today’s increasingly vitriolic political atmosphere, greater protections for privacy and free speech are vital.

Despite more than six decades of rulings from the Supreme Court upholding the privacy rights of donors to nonprofit causes, efforts to violate personal privacy rights continue unabated in Congress, at regulatory agencies, and in states across the country.[10] Indeed, in 2024 alone, People United for Privacy forecasted legislative threats to nonprofit advocacy and donor privacy in 31 states across the country.[11] The lesson is clear: Precedent alone is not enough to safeguard Americans’ personal privacy. Proactive legislation is needed.

The Speech Privacy Act provides that proactive protection and safeguards Americans’ freedom to join together with their fellow citizens in support of a cause. It empowers all Americans to support the nonprofits of their choice without looking over their shoulder to scan for threats on the horizon. It also protects nonprofit groups that speak about public policy from having their members targeted for retaliation by government officials or groups that oppose their views. In this way, the legislation is both a salve for free speech and a much-needed shield for nonprofits and their members.

State equivalents of the Speech Privacy Act have become law in 19 states to date: Arizona in 2018; Mississippi in 2019; Louisiana, Oklahoma, Utah, and West Virginia in 2020; Arkansas, Iowa, South Dakota, and Tennessee in 2021; Kansas, Missouri, New Hampshire, and Virginia in 2022; Alabama, Indiana, and Kentucky in 2023; and Georgia and Nebraska so far in 2024. In early May, the Colorado General Assembly unanimously passed a version of the Speech Privacy Act – introduced with bipartisan support – that currently awaits the Governor’s signature.[12]

Support for these privacy protections is routinely bipartisan. State privacy protection legislation has been signed into law by both Republican and Democratic governors and been sponsored by both Republican and Democratic lawmakers. Measures have passed unanimously – without a single opposition vote at any point in the legislative process – in both Alabama and Nebraska as well as in Democratic-controlled (Virginia) and Republican-controlled (Indiana) legislative chambers and by voice vote (New Hampshire). These protections have been supported by groups as diverse as state right to life organizations and Planned Parenthood chapters, chambers of commerce and labor unions, and organizations on both sides of debates about our civil liberties. If there’s one issue everyone can agree on in our divided age, it’s the importance of protecting the privacy of Americans who support nonprofit causes.

Every American, regardless of their beliefs, will benefit from the Speech Privacy Act’s protections for free speech and personal privacy and its strengthening of nonprofit causes. People United for Privacy urges Members of Congress to advance this policy to protect the privacy rights of all Americans and the nonprofit causes they support.

II. Privacy opponents smear their ideological foes with a Scarlet Letter D for “dark money” to weaken longstanding legal protections and public support for donor privacy rights.

Opponents of privacy in association on both sides of the aisle frequently label their opponents with the pejorative smear “dark money.” The phrase “dark money” is not an official, legal, or technical term. It is a derogatory label used to smear any group that keeps the personal information of its members and supporters – such as their names, home addresses, and employers – private.

The term “dark money” was pioneered by the now-defunct Sunlight Foundation in 2010 after the U.S. Supreme Court upheld the First Amendment rights of nonprofits and other entities to occasionally advocate independently for the election or defeat of federal candidates.[13] Initially, “dark money” referred to these groups’ newfound ability to spend a limited portion of their funds on political messages while keeping their general donors private. The initial hysteria over “dark money” fizzled, however, when nonprofits continually accounted for less than five percent of campaign spending in subsequent election cycles – and as little 0.6 percent and 0.8 percent, respectively, in the two most recent election cycles.[14]

Today, it is well established that donors who wish to influence elections prefer giving directly to candidates and super PACs – entities that can put all of their funds into campaigning. The “dark money” smear, however, has not gone away. Instead, it has been repurposed by politicians, media, and activists on both sides of the aisle to attack virtually any act of advocacy or speech involving a nonprofit. Far from political advocacy, it’s increasingly common today to hear nonprofits engaged in longstanding educational and issue-based practices – including filing amicus briefs in federal court; supporting voter registration drives; submitting comments to government agencies; attempting to sway public opinion on social issues; advocating for or against legislation; and praising or criticizing elected officials – derided as the work of “dark money” actors.

Americans join and donate to nonprofits to amplify their voices on the issues that matter to them. Countless causes – civil rights, religious liberty, environmental protection, Second Amendment rights, good government, tax policy, and more – have benefited from the freedom to speak about government and public policy without exposing their supporters to harm. Instead of buying into the “dark money” myth, the future of free speech in America depends on a principled defense of donor privacy. Every American has the right to support causes they believe in without fear of harassment or intimidation, and efforts to undermine, weaken, or eradicate this right warrant strong scrutiny.

III. Ill-conceived and slapdash proposals to muzzle alleged foreign interference in the nonprofit sector threaten donor privacy rights and valuable nonprofit advocacy while drowning nonprofits in red tape and incentivizing weaponized enforcement.

Any additional government power to collect information about nonprofit donors creates new opportunities to abuse that power and new risks to Americans’ speech and privacy rights. Even if foreign donors to nonprofits are the target, such measures can be expanded over time in a manner that is detrimental to the privacy of American donors to American nonprofits. Compliance with foreign donor reporting mandates necessarily empowers agencies to demand information on nonprofit donor lists for verification purposes. And, of course, expanded nonprofit reporting requirements increase the likelihood that overzealous or biased bureaucrats will find new justifications for fishing expeditions that expose the identities of American donors to public scrutiny.

The act of contributing to political action committees is protected speech and association under the First Amendment. Nonprofits that do not accept tax-deductible donations may engage in limited political activity, so long as that is not their primary purpose. While nonprofits may not contribute to candidates’ campaigns or traditional PACs, First Amendment precedent protects the right of nonprofits to contribute to independent expenditure-only committees, known informally as “super PACs,” which operate independent of candidates and political parties. Legislation that bans protected speech because an organization may have received a foreign donation is contrary to the First Amendment and constitutes a prior restraint on speech. Furthermore, such prohibitions rely on dangerous theories hostile to speech and privacy rights that have been used to justify proposals meant to undermine First Amendment protections.

Likewise, compliance burdens for nonprofits imposed by such policies must not be overlooked. Nonprofits routinely receive donations without the time, resources, or ability to verify the citizenship status of the donor. These issues are exacerbated when a nonprofit receives an anonymous gift with no capacity or opportunity to verify the donor’s identity and citizenship status. In many cases, it is not possible to obtain such information without expending significant time and effort. The potential compliance costs of a foreign donor reporting regime will bankrupt many volunteer-led or grassroots organizations and will certainly divert precious funds that would otherwise be used in furtherance of nonprofit missions.

The dangers of biased and selective enforcement loom large as well. Given the partisan animations frequently underlying disclosure crusades, it is not a stretch to envision enforcement of such laws occurring on an uneven basis, heavily dependent on the whims of the party in power. Would reproductive rights activists be comforted by enforcement of such laws under a conservative administration? Are pro-life advocates likely to be treated fairly by a liberal administration empowered to assess the veracity of nonprofit filings about an organization’s sources of foreign support?

Abuse by government regulators is hardly the only concern in the enforcement context. Proposals requiring reporting about foreign donors to nonprofits risk empowering an organization’s ideological opponents with a powerful weapon if a third-party complaint process is authorized. Regardless of whether a complaint has merit, it will paralyze the targeted nonprofit, drowning the organization in legal costs, diverting resources from its mission, and sullying the group’s reputation while the complaint process plays out. In this scenario, the process is the punishment.

IV. Because of the privacy, speech, compliance, and enforcement concerns inherent in legislation targeting alleged foreign election interference in the nonprofit sector, such measures must abide by several bright-line rules that safeguard First Amendment-guaranteed speech and privacy freedoms.

Legislative proposals that seek to impose donor reporting or prohibitions on the political and issue-based engagement of nonprofits that receive foreign donations must be carefully considered and narrowly-tailored to avoid unintended consequences and the trampling of vital speech and privacy rights. While PUFP does not endorse any such legislation, we believe the following considerations are crucial to minimizing the harms such proposals are likely to invite:

1. Proposals targeting foreign donors to nonprofits must avoid generalized donor reporting. While donors to candidates and political committees are required to be publicly disclosed, Americans generally possess strong First Amendment rights to keep their beliefs and affiliations private if they so choose. A sweeping disclosure mandate would violate the privacy rights of American donors to American nonprofits in direct violation of established Supreme Court precedent and to the detriment of many valuable causes. The Supreme Court has repeatedly emphasized the importance of limiting the reach of laws that mandate donor disclosure because of the chilling effect this policy has on freedom of speech.[15] Maintaining privacy in association is essential for all Americans to be free to exercise their rights and feel confident in the integrity of our constitutional system of government. Any such policy would achieve little more than undermining decades of First Amendment precedent while enabling misleading smear campaigns against all donors, including Americans, to U.S.-based nonprofit organizations.
2. The mere existence of a foreign donor to a nonprofit should not result in an organization being prohibited from engaging in protected speech. Banning American nonprofits from engaging in political or issue advocacy simply because the organization received a single donation from a foreign individual or entity advances the extreme theory that every donor to a nonprofit should be treated as a contributor to an entity that receives a contribution from that nonprofit. This same theory underlies many of the most significant threats to donor privacy that have been proposed in Congress of late, such as the so-called “DISCLOSE Act.”[16] Nonprofits cannot be forced to sacrifice their right to engage in First Amendment-protected activity as a condition of accepting an otherwise legal donation.
3. Compliance with regulations surrounding the existence of foreign donors cannot be so extensive or inflexible as to make adherence to the law impossible. For example, such restrictions cannot have the impact of criminalizing the receipt of anonymous donations. Anonymous giving is not only a time-honored tradition in American philanthropy but a protected constitutional right. Nonprofits routinely receive donations without the ability or resources to verify the citizenship status of the donor. In many cases, it is not possible to obtain such information without expending significant time and effort, and in some cases, attaining an answer may be impossible.
4. Policies must be included that prohibit a weaponized enforcement process. This necessarily involves protections that allow nonprofits accused of violations to defend themselves from frivolous complaints lodged by their ideological opponents. The burden of proof must be on the actor lodging the complaint, not the accused, and cost-shifting penalties for frivolous complaints should be included in any such legislation.

Adherence to these guidelines will not guarantee that a proposal poses minimal or non-existent concerns from a First Amendment standpoint, but they will go a long way towards limiting the damage to the nonprofit sector and the privacy rights of nonprofit supporters.

V. Expanded disclosure requirements assist foreign adversaries’ efforts to suppress critics and risk making American nonprofits and their supporters targets of foreign government actors.

Instead of protecting American democracy from foreign adversaries, such legislation would likely assist oppressive regimes in their zeal to stamp out valuable pro-democracy work. Exposure of the names and addresses of foreign-based human rights organizations receiving funding from American nonprofits would not only threaten those organizations’ ability to operate in many countries but would also create an immediate safety concern for those affiliated with such organizations.

For example, publicly available data on which American nonprofits are receiving contributions from Chinese citizens, who may be living in the United States, could make those groups targets of sophisticated hacking operations and present legitimate safety concerns for all of their supporters. For Chinese-American immigrants with family in China, handing the Chinese Communist Party such data is likely to be enough to decide supporting nonprofits critical of the CCP isn’t worth the risk to their and their family members’ safety.[17] Similar concerns apply to American nonprofits engaged in support of (or opposition to) Israeli policy, organizations tied to the Catholic Church, and groups working on tax policy or tourism with international ramifications, among countless examples.

Many U.S.-based nonprofits do important work in countries around the globe. And many American nonprofits have deep ties to communities in other countries. Broad disclosure requirements could have a global impact that wreaks havoc on a sizable portion of the nonprofit sector. Indeed, “foreign influence transparency” laws are already employed in authoritarian nations to criminalize the work of organizations deemed “foreign agents.”[18] Instead of bolstering the strength of our democracy against its enemies, these proposals risk aiding our adversaries in their anti-democracy efforts, while also enabling them to excuse criticism of their own speech-suppressing “transparency” laws by pointing to similar American laws.

*             *             *

Laws that invade Americans’ privacy and chill their participation in public life do not belong in any democracy, let alone the United States. Due to today’s highly charged political climate, Americans are increasingly concerned about their private giving being made public and weaponized against them by those who disagree with their views. Unfortunately, their concerns are well-founded, thanks to a growing push for unconstitutional and harmful disclosures in Congress, at federal agencies, and in states around the country. Efforts to force nonprofits to disclose their membership or donor information are among today’s leading threats to the First Amendment rights to freely speak, publish, and support groups that advocate for causes supported by Americans across the country and the ideological spectrum.

When Americans can be silenced through harassment and intimidation because of the causes they support, our elections are transformed from contests over ideas into battles for raw power. Americans deserve confidence that elections are decided based on their views about who offers the best path forward for the country, not which side’s partisans are the most ruthless and effective at silencing their opposition. Americans deserve to trust that when they participate in civic discourse by supporting nonprofits, they will not lose their jobs or face protests – or worse – at their homes.

Legislative efforts to police allegations of foreign electoral interference risk such an outcome, especially if pursued in a rushed or reckless manner. Dangers lurk to longstanding and hard-earned privacy rights and freedom of speech. Support for nonprofit donor privacy protections, like those in the Speech Privacy Act of 2023, is bipartisan and widespread, but legislation aimed at exposing foreign donors to nonprofits directly contradicts such safeguards. Important bright lines must be respected to avoid the worst consequences of such policies, especially in light of the danger that forced disclosure will turn American nonprofits and their supporters into the targets of hostile foreign government actors.

Associational privacy is an enduring First Amendment right that has been repeatedly affirmed by the U.S. Supreme Court for decades and shares widespread support among Americans regardless of their political leanings. We encourage Members of the Committee to proceed cautiously and to seriously question whether the pursuit of novel nonprofit speech restrictions and privacy violations is an appropriate or effective means of addressing allegations of foreign election interference.

Sincerely,

Matt Nese
Vice President
People United for Privacy

[1] People United for Privacy’s vision is an America where all people can freely and privately support ideas and nonprofits they believe in, so that all sides of a debate will be heard, individuals won’t face retribution for supporting important causes, and all organizations maintain the ability to advance their missions because the privacy of their supporters is protected.

[2] Bradley A. Smith, “Celebrate the Citizens United Decade,” The Wall Street Journal. Available at: https://www.wsj.com/articles/celebrate-the-citizens-united-decade-11579553962 (Jan. 20, 2020).

[3] Eric Wang, “Analysis of H.R. 1 (Part One): ‘For the People Act’ Is Replete with Provisions for the Politicians,” Institute for Free Speech. Available at: https://www.ifs.org/wp-content/uploads/2021/02/2021-02-22_IFS-Analysis_HR-1_DISCLOSE-Honest-Ads-And-Stand-By-Every-Ad.pdf (Feb. 22, 2021).

[4] Matt Nese, “Opposition to the DISCLOSE Act and its Destructive Impact on Nonprofit Advocacy and Citizen Privacy,” People United for Privacy. Available at: https://unitedforprivacy.com/wp-content/uploads/2022/07/2022-07-25_PUFP-Letter_US_Senate-Rules-Committee_DISCLOSE-Act-Hearing.pdf (July 25, 2022).

[5] Speech Privacy Act of 2023, H.R. 4471, 118th Cong. (1st Sess.) (2023) Available at: https://www.congress.gov/118/bills/hr4471/BILLS-118hr4471ih.pdf.

[6] American Confidence in Elections Act, H.R. 4563, 118th Cong. (1st Sess.) (2023). Available at: https://www.congress.gov/118/bills/hr4563/BILLS-118hr4563ih.pdf. The Speech Privacy Act of 2023 is located in Sec. 308.

[7] See American Donor Privacy and Foreign Funding Transparency Act, H.R. 8293, 118th Cong. (2d Sess.) (2024). Available at: https://www.congress.gov/118/bills/hr8293/BILLS-118hr8293ih.pdf. The Speech Privacy Act is located in Sec. 3. See also, Preventing Foreign Interference in American Elections Act, S. 4145, 118th Cong. (2d Sess.) (2024). Available at: https://www.congress.gov/118/bills/s4145/BILLS-118s4145is.pdf. The Speech Privacy Act is located in Sec. 3.

[8] Americans for Prosperity Foundation v. Bonta, 594 U.S. at __ (2021).

[9] Luke Wachob, “Privacy Prevails in the Peach State: Georgia Becomes 19th State to Pass the PPPA,” People United for Privacy. Available at: https://unitedforprivacy.com/privacy-prevails-in-the-peach-state/ (May 7, 2024). Georgia became the 19^th state to pass legislation strengthening nonprofit donor privacy protections on May 6, 2024. See Georgia Act 613 at https://www.legis.ga.gov/api/legislation/document/20232024/229599 (May 6, 2024).

[10] In Congress, see, e.g., Alex Baiocco, “Congress Seeks ‘Common Ground’ in Attacking Nonprofits. Let’s Hope They Don’t Find It.” People United for Privacy. Available at: https://unitedforprivacy.com/congress-seeks-common-ground-in-attacking-nonprofits-lets-hope-they-dont-find-it/ (Dec. 19, 2023) and Eric Wang, “Analysis of H.R. 1 (Part One): ‘For the People Act’ Is Replete with Provisions for the Politicians,” Institute for Free Speech. Available at: https://www.ifs.org/wp-content/uploads/2021/02/2021-02-22_IFS-Analysis_HR-1_DISCLOSE-Honest-Ads-And-Stand-By-Every-Ad.pdf (Feb. 2021). At the state level, see, e.g., Alex Baiocco, “Unlikely Allies Thwart Privacy Threat in Oregon,” People United for Privacy. Available at: https://unitedforprivacy.com/unlikely-allies-thwart-privacy-threat-in-oregon/ (April 24, 2024); Alex Baiocco, “Bipartisan Opposition Sinks Multi-Year Crusade to Violate Mainers’ Privacy,” People United for Privacy. Available at: https://unitedforprivacy.com/bipartisan-opposition-sinks-multi-year-crusade-to-violate-mainers-privacy/ (March 4, 2024); and Alex Baiocco, “Oklahoma Lawmaker Asks Ethics Commission to Dox Nonprofit Donors,” People United for Privacy. Available at: https://unitedforprivacy.com/oklahoma-lawmaker-asks-ethics-commission-to-dox-nonprofit-donors/ (Feb. 14, 2024).

[11] Matt Nese and Alex Baiocco, “Forecasting 2024 State Threats to Nonprofit Advocacy and Donor Privacy,” People United for Privacy. Available at: https://unitedforprivacy.com/wp-content/uploads/2024/02/2024-02-12_PUFP-Memo_Forecasting-2024-State-Threats-To-Nonprofit-Advocacy-And-Donor-Privacy.pdf (Feb. 12, 2024).

[12] See S.B. 24-129, 74th Gen. Ass., 2nd Reg. Sess. (Colo. 2024). Available at: https://leg.colorado.gov/bills/sb24-129.

[13] Bill Allison, “Daily Disclosures,” Sunlight Foundation. Available at: https://sunlightfoundation.com/2010/10/18/daily-disclosures-10/ (Oct. 18, 2010).

[14] Helen Knowles-Gardner, “Putting ‘Dark Money’ in Context: Campaign Spending by Nonprofits per Election Cycle,” Institute for Free Speech. Available at: https://www.ifs.org/research/putting-dark-money-in-context-campaign-spending-by-nonprofits-per-election-cycle/ (May 7, 2024). See also, Luke Wachob, “Putting ‘Dark Money’ in Context: Total Campaign Spending by Political Committees and Nonprofits per Election Cycle,” Institute for Free Speech. Available at: https://www.ifs.org/wp-content/uploads/2017/10/2017-05-08_IFS-Issue-Brief_Wachob_Putting-Dark-Money-In-Context.pdf (May 16, 2017).

[15] See, e.g., NAACP v. Alabama ex rel. Patterson, 357 U.S. 449 (1958); Americans for Prosperity Foundation v. Bonta, 594 U.S. at __ (2021). Other prominent cases supporting a right to maintain privacy in one’s affiliations and memberships include, but are not limited to, Bates v. Little Rock, 361 U.S. 516 (1960) (holding unconstitutional a city tax ordinance requiring nonprofit groups to publicly disclose donors); Shelton v. Tucker, 364 U.S. 479 (1960) (holding facially unconstitutional a state requirement that public school teachers list all organizations to which they belonged or contributed to in the past five years, even though the list was not public); and Talley v. California, 362 U.S. 60 (1960) (holding facially unconstitutional a city ordinance requiring handbills to identify financial supporters). For more information, see FN 7 in Bradley A. Smith, “Americans for Prosperity Foundation v. Bonta: Questions and Answers,” Institute for Free Speech. Available at: https://www.ifs.org/wp-content/uploads/2021/08/2021-08-30_Explainer_Smith_Americans-For-Prosperity-Foundation-v.-Bonta-QA.pdf (Aug. 30, 2021).

[16] See note 4, supra.

[17] See, e.g., Dr. Jianli Yang, “When Donor Privacy is a Life or Death Matter,” RealClearPolicy. Available at: https://www.realclearpolicy.com/articles/2022/07/15/when_donor_privacy_is_a_life_or_death_matter_842585.html (July 15, 2022).

[18] See, e.g., Ekaterine Maghaldadze, “Georgia poised to adopt ‘foreign influence transparency’ law akin to Russia’s,” Voice of America. Available at: https://www.voanews.com/a/georgia-poised-to-adopt-foreign-influence-transparency-law-akin-to-russia-s/7600259.html (May 6, 2024).