The Catholic University of America

Prohibited Transactions Policy

Approved by: President
  Issued:    March 14, 2002
  Revised:  August 13, 2014
Related Policies: Conflict of Interest Policy for Staff and FacultyContract Approval and Signature Authority PolicyCorporate Travel Card Policy; Employee Cell Phones for Business Use Policy; Gift Card PolicyGrants and Contracts PolicyProcurement Card PolicyProcurement PolicyReporting Financial Irregularities Policy; Standardization Policy
Additional References:  
Responsible Official: Senior Director, Strategic Sourcing & Business Services, tel. (202) 319-5046

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I.          Introduction

University funds are to be used only to meet the educational, research and public service missions of the University. All transactions must comply with this policy, as well as any applicable policies governing the specific transaction type. The Vice President for Finance and Treasurer has the responsibility to determine minimum acceptable guidelines for expenditures. 

Transactions will be reviewed by the Office of Strategic Sourcing & Procurement and/or the Office of the Associate VP for Finance and Assistant Treasurer as appropriate, and may be subject to disapproval if funds are not available, materials or services can be obtained at a lower price, or if other applicable University policies and procedures have not been followed.  If a transaction is deemed prohibited or unauthorized the individual who engaged in the transaction may be held personally responsible for any related charges incurred.

This policy applies to all faculty, staff and student organizations in the expenditure of University funds.

II.         Prohibited Transactions

The following transactions are prohibited by University policy: 

1.  Purchases of any items, even those for a business purpose, delivered to a home address unless explicitly permitted by another University policy.

2.  Purchases of items for personal use, or purchases in any way of a personal nature.

3.  Purchases that do not comply with applicable University policies such as, but not limited to, the following:

Conflict of Interest Policy for Staff and Faculty

Contract Approval and Signature Authority Policy

Corporate Travel Card Policy

Employee Cell Phones for Business Use Policy

Gift Card Policy

Grants and Contracts Policy

Procurement Card Policy

Procurement Policy

Standardization Policy

4.   Expenditures for computers or technology-related hardware or software unless explicitly authorized by Technology Services.

5.   Payments of political contributions. 

6.   Purchases of gifts, flowers, Christmas cards, or other items of sentiment to employees unless approved by a Vice President or Dean. 

7.   Expenditures for campus parking registration for privately owned vehicles unless the use is required by the terms of the operator's employment contract. 

8.   Purchase, rental, repairs, cleaning or laundering of clothing, including formal wear and academic attire, for personal use. Exceptions are made in the case of employees who are required by the University to wear uniforms or where such clothing is covered by a collective bargaining agreement. 

9.   Expenditures for subscriptions for journals, magazines, newsletters or newspapers for delivery to employees' homes. 

10.  Payments or reimbursements for personal violations, fines, or stolen articles. 

11.  Payments or reimbursements for annual fees for personal credit cards (does not refer to University issued procurement or travel cards). 

12.  Reimbursement of personal credit card delinquency assessments or interest or overdraft charges unless caused by University error. Requests for reimbursement of charges resulting from a University error require the signature of the Associate VP for Finance and Assistant Treasurer. 

13.  Payments for personal memberships in professional organizations unless authorized in writing by a Dean or Vice President who by approving certifies that the membership is required for the individual's job-related responsibilities. 

14.  Payments for personal membership in social, dining, airline and hotel clubs except as expressly approved by the University President. 

15.  Payments or reimbursements of childcare or pet care costs. 

16.  Reimbursements for use of personal airline miles/points for University travel. 

17.  Reimbursement for personal travel expenses when a trip itinerary includes both personal and business-related travel. 

Purchase of an emergency nature must be approved by the Senior Director, Strategic Sourcing & Business Services or the Vice President for Finance and Treasurer

III.         Prohibited Transactions Subject to Other Policies and Regulations

This policy sets the University's standard for prohibited transactions. Sponsored research grants and contracts and other activities may be subject to other requirements. Where other standards are more restrictive than University requirements or standards, the other standards will be followed.