VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U036

policy. Activities may proceed only upon appropriate institutional approval. VCOM will continue to monitor approved foreign relationships and activities, as appropriate, to ensure ongoing compliance with applicable federal and state laws, regulations, funding agency requirements, and College policy. VCOM supports federal efforts to protect research integrity, intellectual property, and national security and shall comply with all applicable federal and state laws, regulations, funding agency requirements, and guidance governing foreign research partnerships, including the Securing Innovation and Research from Adversaries Act, Office of Management and Budget (OMB) guidance, requirements established by federal funding agencies such as the National Institutes of Health (NIH) and the National Science Foundation (NSF), and an subsequent state laws pertaining to the same. 2.1 Restricted Entity Lists For purposes of this policy, foreign adversaries include organizations appearing on federal restricted entity lists, including but not limited to: • Entities formally designated by the United States Department of State, Department of Commerce, or Department of Defense, pursuant to publicly issued determinations, as participating in a military-civil fusion program or malign foreign talent recruitment program. • Entities receiving funding from a foreign source of a foreign adversary country without approval of the Research Security Council. • Entities directly affiliated with and reporting to the Chinese Communist Party's United Front Political Influence System. • Entities formally designated by the United States Department of Department of Commerce, or Department of Defense, pursuant to publicly issued determinations, as participating in a military-civil fusion program or malign foreign talent recruitment program. • The United States Department of the Treasury Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List; • The list of Chinese military companies operating in the United States required by the 126H of the William. M. Thornberry National Defense Authorities Act for 2021 (Public law 116-283) • The Department of State Debarred Parties List; • The Federal Communications Commission Covered List; • Any entity designated under federal legislation restricting biotechnology, semiconductor, telecommunications, military, or national security-related activities; and • Any other list designated by federal law, regulation, executive order, or federal agency guidance. The Office of the President will maintain procedures for reviewing applicable restricted-party lists, which may change periodically. • The United States Department of Commerce Entity List; • The United States Department of Commerce Unverified List; • The United States Department of commerce Military End-User List;

VCOM Foreign Entity Relationships and Institutional Security Policy

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