Faculty & Staff

Subawards with certain debarred or suspended vendors are restricted by the U.S. government’s Executive Orders 12549 and 12689, "Debarment and Suspension", 22 CFR Part 208. If using USG funds for the international project, the PI or his/her designee must confirm that prospective subrecipients are not among debarred vendors listed on the “Excluded Parties List System”. A notation of this confirmation should be made in the project records.

USG regulations also require Columbia University to obtain certification from a subrecipient that they have not and will not support terrorist acts. The University will not fund an entity that does not meet these qualifications or that refuses to sign the certification.

The signed certification should be collected at the time the subaward document is signed by an authorized official of the recipient agency. (See the Subrecipient Certification Regarding Terrorist Financing form, available in Appendix 70 of the ICAP SOPs.)

In addition to ensuring that subrecipients sign and submit the certification, the PI or his/her designee must also confirm that the prospective subrecipient is not on the master list of "Specially Designated Nationals and Blocked Persons" (maintained by the U.S. Treasury’s Office of Foreign Assets Control – OFAC) and the United Nations Security Council Resolution 1267 list. A notation of this confirmation should be made in the project records.