Guidelines for Grant and Contract Management
225. Compliance with Executive Order 13224
Executive Order 13224 - Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism prohibits U.S. individuals or entities from making any contribution of funds to or for the benefit of entities or persons named on the OFAC-controlled (U.S. Treasury Department, Office of Foreign Assets Control) master list of Specially Designated Nationals & Blocked Persons. The University of Chicago is required to comply with EO 13224. A number of private foundation sponsors have recently incorporated the language of the Executive Order into the terms and conditions of awards they make, requiring flow-down and monitoring of subrecipients for compliance.
The University of Chicago is taking certain steps to ensure that no person or entity on the list of Specially Designated Nationals (SDN) or Blocked Individuals maintained by OFAC receives sponsored program research funds via subawards or sponsored consulting agreements.
University Research Administration is responsible for the preparation and signature of all subawards and consulting agreements issued under a sponsored project. Prior to signing these agreements, the signing official or a URA designee will check the OFAC-controlled list of restricted terrorists organizations and individuals to verify that the University does not involve itself in prohibited transactions with SDN or Blocked individuals.
The following clause has been added to the University's subawards boilerplate agreement and will be included in all outgoing subawards executed by University Research Administration:
ANTI-TERRORIST COMPLIANCE. [Collaborator] hereby agrees that all funds, including sub-awards to subrecipients, will be used in compliance with all applicable anti-terrorist financing and asset control laws, regulations, rules and executive orders.
This announcement is for informational purposes. Should you have any questions regarding compliance on this matter, please contact Susan Boone, Interim Director of University Research Administration.
September 2007
