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Subaward Monitoring and Management - D11
The purpose of this procedure is to execute the OHIO obligation regarding the proper monitoring and stewardship of sponsored funds when those funds are used to issue a subaward to a subrecipient. As a condition of an award made to OHIO, the University is obligated to comply with applicable federal, state, and local regulations. When the University assigns responsibility to a subrecipient for conducting a substantive portion of the work under an OHIO award, the University remains responsible to the sponsor for the management of funds and meeting performance goals. Thus, the monitoring of technical and financial activities associated with a subrecipient is an integral part of the University’s stewardship of sponsor funds.
However, Biden s EO is as similar to Bush s EO
as an atomic bomb is to a sniper rifle.
Bush s EO targeted
inancing terrorism
. It defined terrorism clearly and narrowly. It minimized legal jeopardy to US persons. It did not strip away the standard for criminal liability requirements of action and intent. It did not target spouses or children of accused individuals. Additionally, Bush made a legally meaningful promise to use it with due regard to culpability and the Bush administration used it with restraint. Even so, Democrats criticized it harshly, opposed it, and fought it in courts.
In contrast, Biden s new EO is directed
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