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.