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flowing down anti-terrorism language in subaward

  • 1.  flowing down anti-terrorism language in subaward

    Posted 02-13-2019 15:19

    Global Community members:

    I need to flow down language from a US non-profit prime award to a university subrecipient in The Netherlands.  The prime states:

    "You hereby confirm that Iowa State University complies with all U.S. anti-terrorism laws and regulations, including Executive Order 13224 and the Global Terrorism Sanctions Regulations set forth in 31 CFR Part 594."

    Our subrecipient argues that they are not subject to these laws and can't comply.  I'm looking for alternatives that will enable me to adequately address the intent of the Prime in our subrecipient agreement.

    Thank you for any suggestions!

    Keith Kutz, MS, CRA
    Senior Award Administrator
    Office of Sponsored Programs Administration
    Iowa State University
    Ames, IA 50011-2103