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Policy 2.123
Export Controls and Restricted Party Screening in Procurement and Payment Applications

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Responsible Official: Vice President for Finance/Chief Finance Officer
Administering Division/Department: Payment Services
Effective Date: February 13, 2014
Last Revision: February 13, 2014

Policy Sections:

Overview

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).

Applicability

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.

Policy Details

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

Related Links

Contact Information

SubjectContactPhoneEmail
Policy  Sarah Putney, Director of Administrative Compliance  404-712-9750  sputney@emory.edu 
Procurement Services  Loette King, Senior Director, Procurement & Contract Administration  404-727-0909  lking2@emory.edu 
Payroll  Joleen Mitchell, Director  404-727-6137  jmitch2@emory.edu 
Office of Sponsored Programs  Holly Sommers, Director, Grants Administration (pre-award)  404-727-2507  hsomme2@emory.edu 

Revision History