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Congress prohibits direct payment to Native communities for ceded land.

Date: 1837

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As an alternative mechanism for land purchases, the U.S. government sets up payments to be held "in trust"–a practice that continues to today. "Placing tribal land into trust is a process whereby the secretary of the Department of the Interior acquires title to property and holds it for the benefit of a Native American tribe or individual tribal members" (NCSL).