The Export Control Office compiles, completes, and submits required foreign financial disclosures to the federal government on behalf of the UO. The office collects potentially reportable transactions from individual units across campus and aggregates the data to determine if reporting thresholds described below have been met.
Department Responsibilities
Departments are responsible for internally reporting incoming gifts and contracts from foreign entities to the Export Control Office.
Central offices, such as Purchasing and Contracting Services, Sponsored Projects Services, and UO Advancement, internally report gifts and contracts of which they are aware to the Export Control Office on behalf of departments.
However, departments that enter into a contract with a foreign source or receive a gift from a foreign source are responsible for internally submitting information about that financial transaction. The Export Control Office conducts biannual outreach (in July and January) to departments most likely to have reportable transactions.
Reporting Under the Higher Education Act: Incoming Gifts and Contracts from Any Foreign Source
Under Section 117 of the Higher Education Act, universities that receive federal financial assistance under Title IV, like the University of Oregon, must report incoming gifts and contracts from foreign persons and entities of $250,000 or greater. The reporting threshold is determined at the institutional level, not at the individual department level, and the reporting threshold can be met by one or more gift or contract with the same foreign source. Section 117 reporting occurs biannually (due July 31 and January 31) for reporting periods January 1 – June 30 and July 1 – December 31.
Reporting Under the CHIPS and Science Act: Incoming Gifts and Contracts from a Foreign Source in a Country of Concern
Under the CHIPS and Science Act, universities that receive funding from the National Science Foundation, like the University of Oregon, must report incoming gifts and contracts from foreign persons and entities located in a country of concern of $50,000 or greater. The reporting threshold is determined at the institutional level, not at the individual department level, and the reporting threshold can be met by one or more gift or contract with the same foreign source. The report occurs annually, due October 31, for a reporting period of July 1 – June 30.
Currently, foreign countries of concern are the People’s Republic of China, the Democratic People’s Republic of Korea, the Russian Federation, the Islamic Republic of Iran. Macau, Hong Kong, and Taiwan are not considered part of the People’s Republic of China for the purposes of CHIPS and Science Act reporting.
The UO must report visiting scholars who are "self-funded" as in-kind support to the institution when the dollar amount of the contribution is $50,000 or greater and originates in a foreign country of concern. In addition, the UO must report a gift or contract made directly to an individual employee if that gift or contract originates in a foreign country of concern, is $50,000 or greater, and the institution is aware of it. Please note that if the employee is also listed as principal investigator or senior/key personnel on a federal research award, they may be required to disclose the gift or contract in Current or Pending (Other) Support documents submitted to federal sponsors.
Consequences of Noncompliance or Inaccurate Reporting
Consequences of noncompliance with Section 117 and CHIPS and Science Act reporting can be severe. Noncompliance with Section 117 can lead to the termination of Title IV eligibility, meaning the institution would lose access to federal student aid programs. The Trump Administration’s Executive Order 14282 makes accurate reporting under Section 117 a condition of receiving federal grant funds. Noncompliance with CHIPS and Science Act reporting can include potential penalties and restrictions on future funding.
Contact
Questions about foreign financial reporting can be directed to Director of Conflicts of Interest and Export Controls Mandy Gettler Brown using the button below.