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Business and Operating Policies and Procedures
Policy: 4.20 Transactions Involving Foreign Adversary Countries
Adoption Date: August 25, 2025
Purpose
Howard College adopts this policy to comply with Executive Order GA-48 and protect institutional data, infrastructure, and national security from risks associated with foreign adversary countries.
Scope and Definitions
A foreign adversary is a country or government on the U.S. Department of Commerce’s foreign adversaries list under 15 C.F.R. § 791.4.
This policy applies to all employees, or similarly situated contractors that research, work on, or have access to critical infrastructure as part of their work at Howard College. On the date of this policy “Foreign adversaries” include Peoples Republic of China, including the Hong Kong Special Administrative Region and the Macau Special Administrative Region (China), Republic of Cuba, Islamic Republic of Iran, Democratic People’s Republic of Korea (North Korea), Russian Federation (Russia), and the Venezuelan politician Nicolás Maduro (Maduro Regime). “Critical infrastructure” refers to essential systems like communications, cybersecurity, power grids, and water treatment.
Critical Infrastructure Roles
Employees that research, work on, or have access to critical infrastructure must have this noted in their job descriptions and report related activities annually to the Chief Informational Officer. These employees must undergo reviews for security risks or foreign affiliations through DPS or contract for these review services in consultation with DPS before procuring services.
Prohibited Gifts and Contracts
Employees may not accept gifts (including grants or travel support) from foreign adversary entities. They also may not enter into contracts with individuals or entities affiliated with foreign adversaries, according to federal guidelines. Exceptions require written approval from the President.
Foreign Talent Programs
Participation in foreign-sponsored talent recruitment programs, such as China’s Thousand Talents Program, is prohibited. Any suspicious offers or outreach must be reported to Human Resources or the President’s Office.
Travel Restrictions and Compliance
Professional travel to foreign countries that are on the foreign adversary list is not allowed. Personal travel is allowed with the following guidelines. The PRE FOREIGN TRAVEL DISCLOSURE FORM must be filled out and submitted to your supervisor within 10 days prior to travel and upon returning the POST FOREIGN TRAVEL DISCLOSURE FORM must be filled out and submitted to your supervisor within 10 days of return. Completed forms will be forwarded to the Chief Human Resource Officer. Employees may not bring college devices, access systems, or share non-public information while abroad. (Forms may be found on the Hawk Hub.)
Enforcement and Review
Violations of this policy may result in disciplinary action including termination. The policy will be reviewed every three years by the Chief Human Resource Officer and the President.
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