Compliance

Based on requirements from the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), U.S. Department of State (“State Department”) and the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”), Harvard University has set forth certain guidelines and processes to ensure the University, including schools like HGSE, are taking reasonable measures to avoid engaging with entities or individuals who are a restricted party or employed by or affiliated with a restricted party and are listed on a Restricted Parties Lists (“RPLs”). Specifically, HGSE is expected to screen all international individuals and entities (including learners, attendees, speakers/panelists, organizers/vendors, clients, program and event hosts, and banks) participating in “educational programs” that HGSE, alone or with others, (1) hosts online or in person with an online option, or (2) sponsors, hosts or organizes outside the United States prior to engaging with them to ensure they are not on a RPL. Additionally, (3) for programs hosted in the U.S., screening is required if the content to be presented is subject to export control; certain technologies, software, and data, among other content, could fall into this category.

“Educational program” is broadly defined to include executive and continuing education, not-for-credit summer courses, online programs, workshops, conferences, symposia, and other services and events that have an educational component, regardless of source of funding (sponsored or non-sponsored). Such “educational programs” may be embedded as an element of a sponsored activity, such as a research grant; some may be a single offering or in a series of offerings. All such dimensions require a screening duty if the criteria are met above.

If screenings are required, those should be done before any payment is accepted from the individual and/or before the educational offering is provided to the individual. This may require units to build in an additional step into their registration processes.

The screening requirement supports enforcement of economic, and trade sanctions put in place by the U.S. Treasury Department and the U.S. Department of State. Their sanctions lists are regularly updated, so screening must take place prior to the start of each program.

At HGSE, the primary duty to screen rests with HGSE’s Export Control Officer (ECO) who is informed of the screening need by Principal Investigators (PIs), faculty, administrators and those who have knowledge of the “educational offerings.”

However, if the volume and frequency of screenings is over a certain amount, an individual within the HGSE center, lab or unit can be assigned a screening role and granted access to the Visual Compliance software used to screen. The guidance below is for use by such an individual assigned to complete Restricted Party (also known as Visual Compliance) Screenings .

For more information:
Specially Designated Nationals (SDN) List Screening Process and Monitoring guidance
Export Control Policies and Procedures

Screening of Attendees Not Required

Program is hosted by Harvard University* and is:
Exclusively in-person on Harvard’s campus in the U.S. OR
Offered online (including hybrid) or outside the U.S. and:
- Open to the public, and
- No registration beyond name and email address to access livestream, and
- No registration fee or other financial transaction.
Program or event is NOT hosted, sponsored, funded, or organized by Harvard (alone or with others*.)

*NOTE: Screening is REQUIRED if program content is export controlled or if the program or event is physically taking place in a country subject to comprehensive sanctions (currently: Cuba, Iran, North Korea, or the Crimea Donetsk People’s Republic, or Luhansk People’s Republic areas of the Ukraine.)

*Screening is required of non-Harvard hosts, sponsors, funders, and organizers.

Screening of Attendees Required

DO NOT PROCEED without screening if one or more apply:

Providing online (including hybrid) education to non-U.S. persons, other than described above in “No Screening Required.”
Hosting, sponsoring, funding, or organizing (alone or with others) a program, conference, or other event abroad.
Providing honoraria or travel reimbursements to non-U.S. persons.
Program content is export controlled.*

*Most catalogue course content is not considered export controlled. However, when in doubt, contact your School or Institute’s ECO (Export Control Officer.)

Collaborative Institutional Training Initiative (CITI)

Collaborative Institutional Training Initiative (CITI) training provides essential, web-based education on research ethics, compliance, and regulations, especially for human subjects research.

Export Control Laws and Regulations (University-Wide)

This 30-minute course provides administrators and researchers with an introduction to export control laws and regulations, and how they may impact University research activities.

Field Research Compliance, Safety and Security, and Fieldwork Best Practices

Harvard university considers field research, field studies, and fieldwork an essential component of its scholarly activities, therefore, whether research and scholarship occur in the field or on campus, the University expects that all activities will be conducted in a safe and compliant manner aligned with the university expectations and policies.

Outside Activity and Interest Reporting (OAIR)

The OAIR application is Harvard University’s electronic system of record for the reporting and review of faculty and researchers' outside professional activities and other relevant interests, automating the submission and review process, storing documents, and providing reports.

Participation Agreement and Visiting Participation Agreement

This policy applies to all members of the University and visitors who perform research in Harvard facilities.

Research Security Training (University-Wide)

This training provides recipients of federal research funding with information on risks and threats to the global research ecosystem.

Responsible and Ethical Conduct of Research (RECR)

The responsible and ethical conduct of research (RECR) is critical for excellence, as well as public trust, in science and engineering. RECR involves not only a responsibility to generate and disseminate knowledge with rigor and integrity, but also a responsibility to:

1. Conduct peer review with the highest ethical standards.
2. Diligently protect proprietary information and intellectual property from inappropriate disclosure.
3. Treat students and colleagues fairly and with respect.

Education in RECR is considered essential in the preparation of future scientists and engineers.

Responsible Conduct of Research Program (RCR)

RCR consists of a basic course, refresher course, communicating research findings course, and facilitator guides. While particular emphasis is given to the educational needs of graduate students and postdoctoral researchers, the RCR series is suitable for any person involved in research ranging from upper-level undergraduates to established faculty and other professionals.

Contact Us

For grant-specific questions, please contact your research portfolio manager. For other inquiries, or if you are unsure whom to contact, email Tiffany Blackman.