Hi Laura,
You are certifying regarding individuals and entities "known to us", so as long as you do check the lists, you should be able to accept the funding from an Iranian company. I think that as long as Karolinska does its due diligence and checks the various U.S. government, UN, and EU lists of restricted and prohibited parties, then you comply with this language. We would search the lists for both the name of the entity and, when available, individual names of leaders (for example, a chief financial officer) associated with the organization in Iran.
Hope this helps!
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Janet Simons
Director, Research Policy
University of Maryland Baltimore
Baltimore, MD
Original Message:
Sent: 12-07-2015 09:34
From: Laura Plant Fuentes
Subject: Embargoed countries and US donations
We have some funding from US donations that have clauses such as those below. Our lawyers want to know if we are able to accept funding from an Iranian company to fund a PhD student. From my understanding we are able to since the company is not known to support violence or terrorist activities but just want to check what others thought!
The Grantee certifies that:
… we do not engage in transactions of any kind with vendors, contracting organizations, or any other entities known to us to support violence or terrorist activities, and we do not otherwise disburse any of our funds, as grants or in any other form, to individuals or entities known to us to support violence or terrorist activities;
(d) We have reviewed the lists of individuals or organizations identified by the U.S. government, the United Nations or the European Union as associated with terrorism and none of our affiliates, subsidiaries, vendors, other contracting organizations, grantees or other entities with which we engage in transactions appear on those lists.
Thanks for your feedback!
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Laura Plant Fuentes
US Grants Coordinator
Karolinska Institutet
Stockholm, 17177
(085) 248-7649
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