Foreign Adversary Nations (III.B.7)

Volume ­­III: Ethics
Chapter B: Conflicts
Responsible Executive: Vice President for Ethics and Compliance
Responsible Office: Office of the Vice President for Ethics and Compliance
Date Issued: June 30, 2025
Date Last Revised: December 1, 2025

Table of Contents

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

Contacts

Policy Clarification

Vice President for Ethics and Compliance
765-494-5830 | vpec@purdue.edu

Statement of Policy

Purdue University complies with all federal and state laws, regulations and orders regarding Foreign Adversary Nations and Foreign Adversary Entities. In so doing, the following prohibitions and restrictions are in place:

1. No officer, Employee or agent of the University may commit or disburse funds or sign contracts or other written instruments on behalf of the University, either directly or indirectly through an intermediary or affiliated organization, with a Foreign Adversary Entity without receiving approval from the Chief Financial Officer, or designee.
2. All gifts proposed or offered from sources located in a Foreign Adversary Nation and valued at $10,000 or more in a calendar year, alone or combined, must immediately be reported to the Chief Financial Officer, or designee, who will determine whether it is in the best interest of the University to accept, decline, or return the gifts. Gifts below the above amount must be declined if the donor is known to be located in a Foreign Adversary Nation. If the donor’s affiliation is not known until after the gift is accepted, the Chief Financial Officer, or designee, will determine whether to retain or return the gift.
3. Gifts from and contracts with foreign sources, whether or not related to a Foreign Adversary Nation or a Foreign Adversary Entity, must be reported in accordance with applicable state and federal law.
4. All bids or proposals for contracts for goods or services must include a certification that the company, and, if applicable, any of its holding companies, affiliates, or subsidiaries, is not a Restricted Vendor.
5. No Employee of the University may participate in a foreign recruitment program of a Foreign Adversary Nation.
6. No officer, Employee or agent of the University may authorize the transfer, licensing, or sublicensing of intellectual property created or developed using university resources to a Foreign Adversary Entity.
7. No officer, Employee or agent of the University may authorize a visiting scholar funded by a Foreign Adversary Nation and/or by a Foreign Adversary Entity.

This policy provides an overarching summary for the application of government mandates that pertain to Foreign Adversary Nations. Where a topic is addressed in another policy, this policy defers to that policy for details. Refer to the Related Documents, Forms and Tools section for a list of related policies.

Reason for This Policy

In an effort to protect and strengthen the nation’s economy and security, federal and state governments have enacted laws, regulations and orders regarding dealings with Foreign Adversary Nations. This policy endeavors to consolidate in one source the areas and activities of the University affected by these mandates.

Individuals and Entities Affected

All Employees, offices, departments, colleges, schools and other units of the University.

Exclusions

There are no exclusions to this policy.

Responsibilities

Vice President for Ethics and Compliance

• Oversee the coordination of university policies and procedures for compliance with governmental requirements related to Foreign Adversary Nations.

Chief Financial Officer

• Ensure federal and state reporting requirements pertaining to gifts from or contracts with Foreign Adversary Nations are met.

Definitions

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.

Employee
Faculty and staff of the University employed full- or part-time. This definition does not include contractors or others paid by third parties, visiting scholars, or positions defined in the policy on Appointments for Personnel Not on Payroll (VI.B.3).

Foreign Adversary Entity
A business, governmental entity, or other entity (or any of their agents, trustees, or fiduciaries) organized under the laws of, headquartered in, or owned or controlled by citizens or the government of a Foreign Adversary Nation.

Foreign Adversary Nation
A country as defined from time to time in 15 CFR 7.4 or designated so by the governor of Indiana under IC 1-1-16-8.

Restricted Vendor
A company  that is:

1. Listed in Section 889 of the 23019 National Defense Authorization Act (NDAA);
2. Listed in Section 1260H of the 20221 NDAA;
3. Owned by the government of a county, or controlled by any governing or regulatory body located in a country, on the U.S. Department of Commerce’s foreign adversaries list under 15 CFR 791.4; or
4. Included on or controlled by an entity on the Specially Designated Nationals (SDN) list maintained by the U.S. Department of Transportation’s Office of Foreign Asset Control (OFAC).

Related Documents, Forms and Tools

Office of Research definitions page – includes foreign countries of concern and foreign adversaries

Policies:

• Charitable Donations to the University (II.B.2)
• Conflicts of Commitment and Reportable Outside Activities (III.B.1)
• Delegation of Authority and Responsibility for Making and Executing University contracts and Written Agreements (Except Employment Contracts) (EVPT A-19)
• Delegation of Signature Authority for Approving the Obligation of University Funds for Procurements of Services, Supplies and Expenses, and Capital (EVPT A-35)
• Export Controls and OFAC Regulations (I.A.2)
• Individual Financial Conflicts of Interest (III.B.2)
• Intellectual Property (I.A.1)
• Research Security Program (I.A.6)

Indiana House Enrolled Act 1179

State of Indiana Executive Order 25-64

Code of Federal Regulations: 15 CFR 7.4 and 15 CFR 791.4

Website Address for This Policy

www.purdue.edu/vpec/policies/ethics/iiib7

History and Updates

December 1, 2025: Interim status removed.

September 18, 2025: Added prohibition on visiting scholars to the Statement of Policy.

June 30, 2025: This is the first policy to consolidate all federal and state mandates related to foreign entities and nations.

Appendix

There are no appendices to this policy.