This is where the Attorney General can be your friend.  Since the Attorney General is probably the only person who can object to your making the transfer, it makes sense to ask the Attorney General to give you a letter of no objection.  It is not a lot of money, but if you can get protection for your directors who make the decision, you ought to try to do so. 

In the future, try to give yourself some wiggle room in solicitations, saying you plan to use the money for a special project, but will use it for other purposes if the project doesn’t happen or you get more than you need.