Published: Sept. 1, 2022

Since joining the Campus Controller’s Office in March of this year, I have been thrilled to dive into diverse compliance projects, like internal risk reviews and external regulatory reporting. Risk and reporting are the bread and butter of compliance work, and I am very excited to be working on them for CU Boulder in general and the Controller in particular.

Reach out!

Please contact me if:

  • You have any questions or concerns about possible officer conflicts or the disclosure process.
  • You believe your department generates a type of revenue that could be a gift or contract, but which you have not reported in the past through our established biannual process.

Patricia Santiago
Assistant Director • Fiscal Compliance

For our campus partners, there are a few events on the horizon that I would like to bring to your attention.

Upcoming Events

If you are an officer or a campus partner, be on the lookout for two reporting events: our officer conflict of interest certification and our foreign gifts and contracts report.

Officer Conflicts of Interest Disclosure 

Public trust is critical to the mission and reputation of the University of Colorado Boulder. For this reason, we ask our officers to disclose personal outside interests or activities that may potentially conflict with the university’s interest or mission. Such conflicts are not necessarily prohibited, but they must be managed appropriately if present. If you are an officer, you will receive a link to a disclosure form this month. You will also receive additional guidance on what may constitute a conflict and what may be reportable.

Foreign Gifts and Contracts Reporting

The Department of Education requires biannual reports from the university on certain gifts and contracts from foreign sources and their U.S. agents. If you are a campus partner, please prepare for the next round of reporting by carefully revisiting your department’s sources of revenue.

Which of your revenue sources could be defined as a gift or a contract?

Gift: Contributions of money or property. They may be received directly by the department or through the Foundation. Anonymous gifts are not exempt from reporting.

Contract: An agreement for acquisition by purchase, lease, or barter for the direct benefit or use of either of the parties. This may include grants, data use agreements, IP licensing agreements, material transfer agreements, service agreements or fees, and barter agreements.