Good afternoon: I am sending this to a few different groups given the relevancy to several areas we are following. I am attaching an exhibit from the SF v. Trump Executive Order litigation that contains some information on FEMA grants and DHS standard terms and conditions. (Here is a direct link to the DHS terms and conditions but I couldn't find the FEMA memo so included it from the attached declaration). https://www.dhs.gov/sites/default/files/2025-03/2025_0327_fy2025_dhs_terms_and_conditions_version_2_0.pdf * In particular, the FEMA memo discusses the approval of FEMA-administered grants for so-called sanctuary jurisdictions. The memo lists non-disaster grants that FEMA recommends restrictive immigration conditions be placed on (see p. 6 of the PDF). * On the standard terms and conditions for DHS, see starting on p. 32 of the PDF where it talks about immigration conditions. These look fairly familiar from the last go-round, but there are some tweaks to them. They will require compliance with 1373, 1644, and 1324. They will require recipients to honor detainer requests and provide access to detainees and to not leak or publicize immigration enforcement operations. The conditions also note that these requirements are material, though it doesn't specifically mention the false claims act. * On p. 34 of the PDF the standard terms and conditions contain a requirement that recipients must certify that they do not, nor will they operate or advance or promote DEI, DEIA, or "discriminatory equity ideology" in violation of federal anti-discrimination laws. The recipients are also required to certify that they will not engage in a "discriminatory prohibited boycott." DHS reserves the right to terminate and claw back funds if this term is violated. * There is a False Claims Act requirement on p. 34. * Note that the terms and conditions also state that: DHS may terminate the award "Pursuant to the terms and conditions of the federal award, including, to the extent authorized by law, if the federal award no longer effectuates the program goals or agency priorities." Thanks, Amanda [logo]<https://imla.org/> [facebook icon]<https://www.facebook.com/InternationalMunicipalLawyersAssociation/>[twitter icon]<https://twitter.com/imlalegal>[linkedin icon]<https://www.linkedin.com/company/international-municipal-lawyers-association-inc./> Amanda Karras (she/her) Executive Director / General Counsel International Municipal Lawyers Association P: (202) 466-5424 x7116 D: (202) 742-1018 51 Monroe St. Suite 404 Rockville, MD, 20850 Plan Ahead! See IMLA's upcoming events<https://imla.org/events/>, calls and programming.