compliance checklist intl programs oct2010 by 6195nl1


									Harvard University
International Business Operations

Compliance Checklist

Category     Question or Discussion topic                                                                                Follow up questions/other considerations

             General discussion about program activity
                      Type of Activity: Research; Education; or Other                                                    Medical supplies used? Human subject research (medical)?
                      Start Date of Activity                                                                             Other Harvard schools involved in program?
                      Projected End Date                                                                                 Activities which may be politically sensitive?
                      Total budget                                                                                       Were you required to obtain permits or government approvals?

           Is the project subject to a formal planning process? Have project goals and objectives been communicated
           to key stakeholders?                                                                                          Process for revising plans?
           Is there a formal project oversight body domestically or internationally? If yes, does the body have a formal What process occurred internally in your school to approve your
           charter?                                                                                                      project?
           What accountabilities for this project exist back in Cambridge/Boston?
           Are major decisions about the project made by people in Cambridge/Boston or in the foreign country?

             Has a registration of any kind been filed with the local government or tax authority?                       If so, was it registered as separate legal entity?
             What are the legal or statutory filing requirements?
             How is the Harvard name being used in the foreign country?
             Are there any contracts or MOU's with other orgs or companies in that country?                              Can we obtain copies?
             Where does Harvard conduct business outside that country?
             Do you engage a local law firm?                                                                             If not, where do you obtain legal support?
             Is there any ongoing or pending legal actions or other "significant" in-country disputes?

Personnel and Payroll
            Are people from the US working inside host country for longer than six months per year?                      if so, how are taxes being paid locally?
            Are there employees of this entity or contractors hired locally?
            If so, are they expats, TCNs, local hires? (provide breakdown)
            Is there a local payroll? If so, who administers?                                                            Please describe the payroll process.
            If foreign staff is employed, do they need work permits, visa?
            Where do people live or stay?                                                                                Who pays for housing?
            Is there a firm handling benefits for local staff?

Financial Management/Cash Management
            Do you engage a local accounting firm for bookeeping or other services?                                      if not, how is bookeeping, tax filings, etc. completed?
            Is the program subject to institutional tax? (VAT, GST, income tax)
            Is there a local bank account?
            If so, in whose name was account opened?
            What is the process for purchasing?
            Are budgets prepared and monitored for major program activities?
            How are local accounting records maintained and by whom?

Fixed Assets/Real Estate
            Where do employees work from? Is there a project office? Is it leased or owned by Harvard?
            Is there security for the office? Please describe.
            What assets does the project own? Is an inventory maintained?
            Is there insurance for the office, assets?

Funding      Does the program generate any income locally? How does the process operate?
             How is ongoing financial stability assessed and monitored? Is there a financial strategy?
             How is this program funded? Sponsored? Activities coordinated with Central Develoopment Office?             Are funding restrictions monitored for compliance?
             Will this entity be involved in direct fundraising for their own operations, activities?                    If so, what are the considerations for donors?
                                                                                                                         Do donations have to be used in country?
Safety/Emergency Mgmt
           Do students and faculty/staff come over from US?                                                              Is there an evacuation plan?
           Do they register with iSOS?
           Does the program provide orientation for visitors including safety and cultural guidance?
           Are emergency contact details maintained and readily accessible for all staff and visitors?
           Have any in-country emergencies arisen? Please describe. What lessons were learned?
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