Responsible Official: Vice President for Finance/Chief Finance Officer
Administering Division/Department: Payment Services
Effective Date: February 13, 2014
Last Revision: August 20, 2014
This policy ensures compliance with a variety of legal, regulatory, and contractual requirements intended to prevent Emory from making prohibited payments to individuals or entities found on any government-issued restricted, blocked, or denied party lists. Compliance depends on timely screening of prospective vendors and payees and appropriate responses by Emory personnel when Emory identifies listed parties. This policy supplements Emory’s Policy on Export Controls in research applications (Policy 7.11).
This policy applies to all Emory University schools, departments, offices and units. Activities subject to this policy may include, but are not limited to: contracts requiring pre-screening of payees, international subcontracts, procurement transactions, honoraria, payroll, and compensation to research study participants.
Emory University must not enter into contracts, conduct business, or otherwise participate directly or indirectly, in any financial activities with any entity or person found on any government-issued restricted, blocked, or denied party lists. Emory University complies with all applicable legal, regulatory and contractual requirements intended to prevent it from making prohibited payments to individuals or entities, including those from sanctioned or embargoed countries, found on any government-issued restricted, blocked, or denied party lists.
Emory may contract for software services or other appropriate methods to implement appropriate screening of prospective payees. Individuals and entities to be screened include but are not limited to: employees, enrolled students, independent contractors, and other vendors. The Divisions of Finance, Human Resources, and Research Administration will cooperate with requests for data to support such screening.
Efforts to resolve any potentially prohibited payees identified through screening shall be conducted promptly by the Divisions of Finance, Human Resources, and/or Research Administration with the cooperation of other Emory personnel as needed.
Appropriate action to prevent prohibited transactions based on screening results will be taken, which may include but is not limited to: notifying other Emory stakeholders, notifying the prohibited party, terminating contractual negotiations, and cancelling payment or procurement transactions.
Each Emory office involved in the screening, resolution, and response procedures shall keep adequate records of these activities for at least five (5) years. These may include local storage and record-keeping provided by licensed software. Emory policies and procedures for record retention may also apply.
Violations of this policy may give rise to liability including penalties, fines, and/or imprisonment.
Failure to comply with this policy may lead to disciplinary action up to and including unpaid suspension or termination of employment
- Current Version of This Policy: http://policies.emory.edu/2.123
- Bureau of Industry and Security, U.S. Department of Commerce: (http://www.bis.doc.gov/index.php/regulations/commerce-control-list-ccl)
- Emory Policy on Export Controls (in research): (http://policies.emory.edu/7.11)
- Emory University Records & Information Management Record Retention Schedules: (http://records.emory.edu/content/records-retention-schedules)
- Emory Compliance with Procurement Policies: (http://policies.emory.edu/2.88)
- Other Emory University Finance Division Procurement and Payment Services information: (https://www.finance.emory.edu/home/Procure%20and%20Pay/index.html)
Subject Contact Phone Policy Sarah Putney, Director of Administrative Compliance 404-712-9750 email@example.com Procurement Services Loette King, Sr Director, Procurement, Contract Admin & Payment Services 404-727-0909 firstname.lastname@example.org Payroll Joleen Mitchell, Director 404-727-6137 email@example.com Office of Sponsored Programs Holly Sommers, Director, Grants Administration (pre-award) 404-727-2507 firstname.lastname@example.org